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 California Air Resources Board 

and approved for publication. Approval does not signify that the contents 

necessarily reflect the views and policies of the Air Resources Board, nor does 

mention of trade names or commercial products constitute endorsement or 

recommendation for use. 
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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 Strategies Section 

CONTRIBUTORS 

Air Quality and Transportation Planning

Kurt Karperos, P.E., Chief, Air Quality and Transportation 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 Analysis Section 

Gayle Sweigert, Manager, Air Quality Analysis Section 

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 Branch 

Vernon Hughes, Manager, Atmospheric Modeling and Support 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 Specialist 

Larry Hunsaker, Air Pollution Specialist 
ACKNOWLEDGMENT 

ARB staff thanks the staff of the San Joaquin Valley 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 Plan 

B. Emissions Inventory 

C. Air Quality Modeling 

D. Reclassification to Extreme Nonattainment 

E. Control Strategy 

F. Attainment Demonstration 

G. Reasonable Further Progress and Contingency Measures 

H. Transportation Conformity Budgets 

I. Additional Requirements for Extreme Nonattainment 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 Joaquin Valley Air 

Basin: Ozone 

Appendix C Photochemical Modeling Protocol for Developing Strategies to 

Attain the Federal 8-hour Ozone Air Quality Standard in Central 

California 

Appendix D Proposed Updates to the Transportation Conformity Budgets 

Identified in the San Joaquin Valley 2007 Ozone Plan 
May 30, 2007 ii 

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May 30, 2007 iii 

EXECUTIVE SUMMARY 

On April 30, 2007, the San Joaquin Valley Unified Air Pollution Control 

District (District) adopted the 2007 Ozone Plan. The 2007 Ozone Plan charts the 

course to attainment of the federal 8-hour ozone air 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. Environmental Protection Agency 

(U.S. EPA) as a State Implementation Plan (SIP) revision. 

The topography of the San Joaquin Valley, combined with hot, dry summers, 

creates an environment very conducive to ozone formation, especially in the 

southern end of the Valley which most frequently experiences the highest ozone 

levels. This, combined with the physical environment and the emissions from 

cars, trucks, tractors, and industrial sources, results 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 than the South Coast Air Basin. 

The federal ozone standard is exceeded by 30 percent, based on the 2006 

design value. 

California has led the nation in reducing public exposure to harmful air pollution 

through the development of emission control regulations on both mobile and 

stationary sources. The rules and regulations in place today are already 

providing air quality improvement, measured by the 8-hour standard. However, 

progress indicators present a mixed picture. The average number of days 

exceeding the federal 8-hour ozone standard has declined 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 design 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 residents experience those 

elevated levels on fewer days. 
May 30, 2007 iv 

Figure EX-1 

Air quality modeling indicates that attainment of the 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 today’s levels in order for 

the region to reach attainment of the standard. Reducing 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 attainment of the 8-hour ozone 

standard more quickly. However, air quality modeling indicates that while 

important, ROG emission reductions do not have the same relative benefit as 

NOx emission reductions, especially in the areas with the worst air quality. 

The U.S. EPA classifies the San Joaquin Valley as serious nonattainment for 

ozone, with an attainment date of June 15, 2013. To 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 emission reductions needed to 

bring the Valley into attainment will come from the implementation of the State’s 

existing mobile source control program, as newer and 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 and 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 ROG goal in 2012. 

A “serious” classification does not reflect the true magnitude of the ozone 

problem in the Valley or the increased stringency of the 8-hour standard. 

Demonstrating attainment of the federal ozone standard by June 2013 as a 
May 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 phase in between 2011 and 2017. 

The federal Clean Air Act (Act) allows, and U.S. EPA recommends, that in these 

cases the area be reclassified to an appropriate higher classification such as 

severe-15, severe-17, or extreme, with attainment dates 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 in the Valley, beyond the 

existing control program, on a very aggressive timeline. On April 30, 2007, the 

District Governing Board adopted a plan which requires additional controls on 

stationary and area-wide sources. 

Both the proposed State Strategy and adopted District plan include commitments 

to develop new emission control regulations and expand incentive programs as a 

mechanism to accelerate the conversion to newer, cleaner technologies. The 

local strategy includes a suite of near-term regulatory 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 constraint 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 more reductions. Therefore, the 

ARB and District staffs will need to continue to develop 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 Joaquin Valley’s 2007 Ozone 

Plan and voted to request that U.S. EPA reclassify the Valley to an extreme 

nonattainment classification. While the ultimate attainment date would be 

extended to 2024, full implementation of the 2007 Ozone Plan would result in 

most regions in the Valley attaining the standard before then. Table EX-1 

demonstrates that the emission reduction commitments 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 attainment date. The 

near-term emission reduction measures approved by the District, combined with 

those proposed by ARB staff, will result in dramatic air quality improvement in the 

San Joaquin Valley. By 2023, only four sites in the Valley will need emission 

reductions, beyond the proposed state measures, in order to attain the federal 

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

 

1

 Available online at: http://www.arb.ca.gov/planning/sip/2007sip/2007sip.htm 
May 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 with ensuring California’s SIP 

compliance, ARB is ultimately responsible for ensuring the necessary measures 

are identified no later than 2020 (three years prior to the attainment year), and 

the emission reductions are achieved by 2023. 

As part of the State Strategy under development, ARB staff is proposing 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 would start an ongoing public process to assess 

technology advancement opportunities for the critical categories. ARB staff will 

periodically brief the Board at public meetings on emerging emission reduction 

opportunities, promising technologies, and the progress made in developing 

long-term emission reduction measures. As ARB staff identifies feasible 

technology-forcing emission reduction measures, staff will propose those 

measures to the Board for inclusion into the SIP. 

The 2007 Ozone Plan, and the request for reclassification, is controversial. 

Many members of the environmental community believe that a reclassification to 

extreme represents an unacceptable delay in attainment of the federal 8-hour 

ozone standard. Based on the air quality modeling conducted for the 

San Joaquin Valley, combined with known emission control technologies which 

will be available, the District believes, and ARB staff concurs, that an extreme 

area attainment plan is the only one that realistically charts the course to clean 

air – which makes it the only federally approvable course of action. 

While a reclassification to extreme is, in the District’s and ARB staff’s view, a 

practical and legal necessity, the District Board approved a dual path strategy for 

attainment. One path includes the commitments and timelines needed in a 

federally approvable SIP, and recognizes the constraints placed on the District by 
May 30, 2007 vii 

State and federal law, policy, and guidance. The second path, which will parallel 

SIP implementation, includes important policy initiatives 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 included actions reflect federally 

enforceable commitments and quantifiable emission reductions. In this 

document, where the district has made an enforceable and quantifiable 

commitment, ARB staff has indicated such. Where the District has committed to 

broader-reaching, yet equally important dual-path strategies, ARB staff has 

indicated this as well. However, only the federally 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 nominal 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 needed 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 needed to attain the PM2.5 

standard to be in place by the beginning of the year 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 reduction targets for attainment and to 

ensure the Valley comes into attainment with the fine particulate standard as 

expeditiously as practicable. 
May 30, 2007 viii 

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May 30, 2007 1 

I. BACKGROUND 

A. Profile of the San Joaquin Valley 

Covering nearly 25,000 square miles, the San Joaquin Valley (Valley) is one of 

the dominant features in California’s landscape. The Valley is one of the fastest 

growing regions in California and is home to more than 3.6 million people. The 

Valley has four large cities, Stockton, Modesto, Fresno, and Bakersfield, with 

populations of greater than 200,000 people. Outside of these cities, the Valley 

has numerous smaller cities and towns, separated by large expanses of 

agricultural lands. While the Valley has large tracts of agricultural land, the 

Valley is very urbanized, and as more and more land is converted from 

agricultural to non-agricultural land uses, this urbanization will continue. 

Open to the Sacramento-San Joaquin River Delta in the 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 Mountains to the south. Airflow 

patterns in the San Joaquin Valley tend to move from 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 nineties, and heat waves 

periodically exceeding 100 degrees Fahrenheit. Winters 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 result in long mixing times for 

emitted pollutants, especially in the central and southern portions of the Valley. 

These stagnant weather patterns make the Valley vulnerable to forming ozone 

and fine particulate matter air pollution and impede the region’s ability to disperse 

it. The ozone season in the San Joaquin Valley spans 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 heavily 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 standard throughout the Valley. 

B. Ozone Health Effects 

Ozone is a highly reactive gas that forms in the atmosphere through complex 

reactions between chemicals directly emitted from motor 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 investigated how people 

respond to inhaling ozone. These studies have consistently shown that ozone 

can lead to inflammation and irritation of the tissues lining the human airways. 

This causes the muscle cells in the airways to spasm and contract, thus reducing 

the amount of air that can be inhaled. Symptoms and responses to ozone 

exposure vary widely, even when the amount inhaled and length of exposure is 

the same. Typical symptoms include cough, chest tightness, and increased 

asthma symptoms. Ozone in sufficient doses can also increase the permeability 

(“leakiness”) of lung cells, making them more susceptible to damage from 

environmental toxins and infection. 

Medical studies of large populations have found that 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 have also associated ozone 

exposure with increased premature mortality. ARB analysis indicates that 

hospitalizations for respiratory related illnesses, not including premature 

mortality, resulting from ozone levels over the federal 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 cardiovascular causes are listed for the 

San Joaquin Valley and compared to the State as a whole. Childhood asthma 

rates are from the California Health Interview Survey, 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 Valley

Percent
May 30, 2007 3 

C. Historical Air Quality 

The Valley is currently classified as serious nonattainment for the federal 8-hour 

ozone standard, and is designated as nonattainment for the federal PM2.5 

standard. Unlike many other ozone nonattainment areas 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 largely developed to reduce 

exposures to 1-hour ozone levels. The average number of days exceeding the 

now-revoked federal 1-hour standard dropped more than 75 percent over the 

past decade. Even with this progress, the 1-hour ozone 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 declined nearly 20 percent 

between 1996 and 2006, the average federal 8-hour design 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

Year

Ozone 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 Value
May 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

Year

Exceedances Days

Federal 8-hour Standard

Federal 1-hour Standard

Because the Valley encompasses a very large geographic area, looking at subregions with similar geography and weather conditions helps provide a better 

understanding of air quality improvements and challenges. Generally, the 

number of days exceeding the level of the 8-hour standard is low in the northern 

region, but dramatically increases from the central to the southern region of the 

Valley. High ozone concentrations are widespread and commonly occur in the 

urbanized Merced, Fresno, and Bakersfield regions, and as well as in the 

downwind areas of Parlier, Sequoia National Park, and Arvin. 

Over the past 10 years, air quality has improved throughout the Valley. On 

average, there were fewer days over the standard between 2004 and 2006 than 

between 1994 and 1996 (Figure 4), with the exception 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 Arvin

Num ber of Exceedance Days

1994-1996 2004-2006

Ozone exceedances in downwind areas such as Arvin and Sequoia National 

Park are a special concern. Arvin is a community of 15,000 people located 

southeast of Bakersfield at the foot of the Tehachapi Mountains. The air quality 

monitor located near Arvin is the site recording the San Joaquin Valley’s highest 

8-hour ozone levels. The 2006 design value2, as monitored at the Arvin site, is 

0.110 parts per million (ppm), over 30 percent above the level of the standard of 

0.084 ppm. This compares to 17 percent above the standard in Fresno and 

18 percent in Bakersfield. Generally, the number of exceedance days at Arvin 

surpasses any other site in the Valley with the possible exception of sites located 

in Sequoia National Park, downwind of the Fresno area. The air quality monitor 

in Arvin records an exceedance 85 percent of the time when there is an 

exceedance anywhere in the San Joaquin Valley. 

Air quality planning in the San Joaquin Valley is further complicated because the 

Valley is also designated nonattainment for the federal 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 value for the annual 

PM2.5 standard is approximately 25 percent above the standard of 15 ug/m3. 

Attainment of the annual standard is the most significant near-term challenge in 

the San Joaquin Valley. The San Joaquin Valley Unified Air Pollution Control 

District (District) is currently developing a PM2.5 attainment plan, which will be 

brought to the District Governing Board in early 2008. 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 comprised 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 central California; and, 2) 

provide decision-makers with the tools needed to identify equitable and efficient 

control methods. 

The studies are a comprehensive multi-year effort of meteorological and air 

quality monitoring, emission inventory development, data analysis, and air quality 

simulation modeling. Combined, the two studies reflect an investment of nearly 

50 million dollars, coupled with extensive in-kind support from study sponsors, 

extending over a 15-year period. The resulting data and analytical tools are 

providing the most advanced scientific understanding available for State 

Implementation Plan development. 

CCOS consists of a field program, data analysis, emission inventory 

development, and modeling. The CCOS field program was conducted during the 

summer of 2000. Emission inventory development, data analysis, and modeling 

are on-going projects. The entire effort is expected to be completed by 2011. 

ARB and the central California air pollution control districts are using the results 

of CCOS to prepare the ozone SIPs for nonattainment areas in central California. 

CCOS provides the most important scientific building blocks for the Valley’s 

current ozone planning effort. 

CRPAQS is intended to evaluate the Valley’s particulate 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 Joaquin Valley routinely 

experiences high levels of particulate matter, and currently exceeds the federal 

annual PM2.5 standard. CRPAQS was designed to address annual particulate 

levels as well as fall and winter episodic conditions. Data was collected for 14 

months (December 1999 through February 2001) throughout the Valley and 

surrounding regions. CRPAQS will provide the scientific 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 or Act) establish the 

planning requirements for those areas that routinely exceed the health-based 

National Ambient Air Quality Standards (NAAQS). These nonattainment areas 

must adopt and implement a SIP that demonstrates how they will attain the 

standards by specified dates. Federal law holds each state responsible for 

implementing the provisions of the Act. 

In the air quality management process, many regulatory 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 California, large new farm and 

construction equipment, locomotives, ocean-going vessels, and aircraft. The 

regional air pollution control districts have primary authority over stationary 

emission sources, including industrial and commercial equipment. The regional 

air districts also develop locally approved air quality plans which, upon approval 

by the ARB and submission to U.S. EPA, become the region’s SIP. 

Ultimately, State law 3 designates the ARB as the State's air pollution control 

agency for all purposes set forth in federal law, including 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 meet the requirements of the CAA.4 

The provisions and commitments in a U.S. EPA-approved SIP are federally 

enforceable. The CAA also allows interested parties to sue U.S. EPA, the State, 

or local agencies to compel implementation of an approved SIP and other 

provisions of the Act. 

B. Recent Air Quality Planning Activities 

Over the past decade, the San Joaquin Valley Unified Air Pollution Control 

District, ARB, and other State and local agencies have adopted a series of 

regulations and measures to improve air quality in the Valley. New mobile 

source standards, reformulated gasoline, and multiple consumer products 

regulations have been adopted and are being implemented today. And, while 

California continues to face serious air quality challenges, it is important to 

recognize the progress made as a result of California’s landmark air pollution 

control programs. 

 

3

 California Health and Safety Code (HSC) section 39602. 

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 (2004 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 measures identified in the 

2004 Plan are being implemented and will provide significant 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 attainment plan which has 

resulted in the Valley coming into attainment of the federal PM10 standard. The 

San Joaquin Valley recently attained the federal PM10 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 data 

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 obligations with respect to the 

existing 1-hour ozone requirements. As described by 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 and 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, Number 209, pages 63641-63664) 

6

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

March 22, 2007, the U.S. Department of Justice petitioned 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 Phase 1 implementation rule 

with a Phase 2 rule.7

 The Phase 2 rule outlines the emission controls and 

planning elements that nonattainment areas must address in their 

implementation plans, including: 

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

standard; 

 adopted control strategies capable of meeting attainment, and contingency 

measures in the event the controls fall short of achieving needed reductions; 

 reasonable further progress plans; 

 demonstration that all reasonably available control technology (RACT) has 

been applied to existing sources; 

 transportation conformity emission budgets to ensure transportation plans 

and projects are consistent with, and will not hinder attainment; 

 a weight-of-evidence analysis; 

In order to demonstrate attainment of the 8-hour ozone standard by the Valley’s 

formal attainment date, all of the emission reductions needed for attainment must 

be in place by the beginning of the full ozone season 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 nonattainment for the federal fine 

particulate matter (PM2.5) standard. PM2.5 plans are due to U.S. EPA in 

April 2008. Recent air quality monitoring data shows that the San Joaquin Valley 

Air Basin attains the 1997 24-hour PM2.5 standard of 65 micrograms per cubic 

meter (ug/m3) of air. The Valley exceeds the annual 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 formation in the Valley. As such, 

the NOx reductions identified in the 2007 Ozone Plan will provide substantial 

progress towards attainment of the PM2.5 standard. The District and ARB staffs 

have begun to identify the magnitude of emission reductions needed to bring the 

Valley into attainment of the PM2.5 standard by 2015. To the extent that the 

NOx emission reductions identified in the 2007 Ozone Plan need to be 

supplemented, the District and ARB will explore opportunities to achieve direct 

PM2.5 emission reductions, particulate precursor reductions from sources such 

 

7

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

as mobile agricultural equipment, as well as additional precursor reductions 

through increased use of financial incentives. 

D. California Clean Air Act Plans 

The California Clean Air Act requires all areas that 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 making steady progress 

towards attainment. Thus far, all districts, including the San Joaquin Valley 

APCD, have relied on the all feasible measures options to show progress. 

Appendix E of the Valley’s 2007 Ozone Plan addresses California Clean Air Act 

planning requirements. Appendix E will not be submitted 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 Plan 

The San Joaquin Valley Unified Air Pollution Control District adopted its 

2007 Ozone Plan on April 30, 2007. This plan charts the course towards 

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

later than the deadline for an extreme nonattainment area. The 2007 Ozone 

Plan contains a dual path strategy, one path constrained by the requirements 

contained in federal law and regulation on an extreme 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 California must submit a federally 

approvable plan, meeting all of the requirements of the Clean Air Act. The 

discussion below focuses on the federally approvable 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 Valley will require continued 

efforts at all levels of government. ARB staff will continue to track promising new 

emission reduction technologies. This will include technologies to ensure that 

new sources are as clean as possible and will leverage technology development 

to keep existing equipment operating at its intended 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 reductions from the on-road trucks 

registered outside of California and locomotives moving 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 cleaner mobile sources. However, 

as the adopted mobile source controls reach full implementation 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 evaluate, 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 pollutants emitted from each source or 

category over a given time period. Emission inventories are estimates of the air 

pollutant emissions that are released into the environment – 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 refineries; 

• Area-wide Sources – consumer products and residential fuel combustion 

for heating homes; 

• On-Road Sources – passenger vehicles and heavy-duty 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 Joaquin 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 2007 Ozone Plan. The 2006 

inventory reflects adopted District and ARB regulations through December 2006. 

Forecast (future year) emissions are based on adopted air regulations with both 

current and future compliance dates. 

The San Joaquin Valley 2007 Ozone Plan uses two types of inventories: a 

modeling inventory used as an input to the air quality model and a summerseason planning inventory used to guide policy-makers in their efforts to identify 

solutions to the ozone challenge. These inventories use the same baseline 

assumptions and data sources. The primary difference is in how the inventories 

are aggregated for use. A modeling inventory reflects where and when the 

emissions are occurring in the region being examined. The planning inventory is 

aggregated by source type and industry sector, and reflects the emissions on a 

typical summertime day. The following discussion focuses on the planning 

inventory used in the San Joaquin Valley 2007 Ozone Plan. 

The planning emissions inventory is divided into four 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 reflects the activity levels and 

conditions that occur when higher ozone levels occur in the Valley. 

In addition to the four major source categories, the modeling inventory includes 

non-anthropogenic emissions. In the San Joaquin Valley, these generally 

include wildfire emissions (if a fire occurred on an episode day) and emissions 

from vegetation. It is critical to include these emissions in the air quality 

modeling exercise, as they play an important role in understanding ozone 

formation in the Valley. 

1. Summary of Emission Sources 

Emission sources in the San Joaquin Valley are diverse. 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 the most productive agricultural 

regions in the world, as well as home to industrial and commercial activities. All 
May 30, 2007 13 

of these sources contribute to the concentrations of pollutants in the Valley. 

Table 1 shows the San Joaquin Valley’s ozone precursor 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 adopted through 2006. 

b – State Measures adopted through 2006. 

c – Numbers may not add up exactly due to rounding.

Mobile sources, including commercial trucks, passenger 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 commercial 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 NOx emissions in the Valley. 

The future year emission inventory projections show reductions are expected to 

occur due to the on-going mobile source emission control program. Table 2 

shows the top 10 sources of NOx emissions in the San 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 top 10 ROG sources in the 

San Joaquin Valley (Table 3), only two individual categories are larger than 

10 percent of the total inventory – passenger vehicles and composting currently 

account for 14 percent and 13 percent, respectively. All other ROG sources, 

including dairy cattle waste, prescribed burning, oil and gas production, and 

recreational boats make up less than 10 percent each when viewed individually. 

When viewed at the larger level, stationary and area-wide emission sources 

account for more than 60 percent of the total ROG emissions. 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 farming equipment. In the 

future, mobile source ROG emissions are expected to decline, as more of the 

vehicles and equipment in operation meet the most stringent emission standards 

required. ROG emissions from stationary and area-wide sources are expected to 

grow in the future, as economic growth outpaces the benefits of the current 

generation of emission control equipment. ROG emissions from waste disposal 
May 30, 2007 15 

and composting alone are expected to increase by more 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 estimates of the pollutant 

emissions that are actually released into the environment. California uses 

computer models to estimate the emissions from on- and off-road mobile 

sources. Stationary source emissions data is derived directly from District 

permitting activities. Area-wide emissions are estimated based on emission 

factors and information on expected activity from these diverse sources and 

undergo routine reevaluation to ensure that they remain up to date and accurate. 

All emission estimates take into account expected growth in activity, state-of-thescience emission data, and currently adopted emission control rules and 

regulations. The growth assumptions used to estimate 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 Measures Discussion, below). 
May 30, 2007 16 

critical elements in any attainment demonstration plan -- they directly impact the 

amount of emission reductions needed to reach the emissions target. 

Stationary source emissions are derived from District 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 Department of Pesticide 

Regulation (DPR). Emission reductions from both ARB and District regulations 

adopted by December 2006 are included in the emission forecasts. 

The mobile source emission inventories used in the 2007 Ozone Plan represent 

many improvements in the models that are used to estimate emissions from both 

on-road and off-road sources. Using the new models, our estimates of the 

emissions generated by mobile sources have increased relative to those used in 

earlier SIPs. These higher estimates do not indicate that actual in-the-air 

emissions are increasing – on the contrary, actual emissions from cars and 

trucks have declined and will continue to decline rapidly over time. This progress 

comes because of State and federal requirements for cleaner engines and fuels, 

and despite significant growth in population and vehicle usage. 

Ozone-related emissions in the Valley are generally consistent with the overall 

downward trend statewide. Although motor vehicle miles traveled in the basin 

continue to increase, on-road vehicle emissions are dropping because of more 

stringent vehicle emission standards and fleet turnover. 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 will decline more steeply. The 

issue before us is not whether, but how quickly emissions from the mobile source 

fleet can be reduced. 

(a) EMFAC2007 

EMFAC2007, California's updated on-road motor vehicle emission factor model, 

was used to generate the on-road mobile source emission inventory for the 

2007 Ozone Plan. EMFAC2007 represents a comprehensive review and 

revision of the on-road inventory when compared to EMFAC2002, which was 

used in previous San Joaquin Valley plans. The major 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. Transportation 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 deterioration for most 
May 30, 2007 17 

categories of off-road mobile sources. The inventory also includes revised 

estimates of evaporative emissions. The extensively 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 published a memorandum 9 outlining 

revisions to the emission estimation calculations for ROG emissions from 

agricultural pesticide usage. These revised inventories 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 calculated 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 Pesticide Regulation and included in Appendix A 

to this report. 

(d) Emission Reduction Credits 

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

sources that increase emissions in amounts exceeding 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 banked, with the District for future 

use as offsets. 

 

9

 California Department of Pesticide Regulation Memorandum. Date: April 6, 2007. Subject: 

Pesticide Volatile Organic Compound Emission Adjustments for Field Conditions and Estimated 

Volatile Organic Compound Reductions–Initial Estimates. Available online at: 

http://www.cdpr.ca.gov/docs/dprdocs/methbrom/comp_modeling.htm 
May 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 treated 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, between 2002 and 2023, is shown in 

Table 5. 

Table 5 

San Joaquin Valley 

Projected ERC Use and Total Stationary Source Growth 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 estimating ERC usage, by 

assuming that all ERCs used will be from pre-baseyear ERCs. The District will 

need to very closely monitor pre-baseyear ERC usage and stationary source 

growth, especially in non-permitted source growth and permitted sources for 

which growth offsets are not required, to ensure that the sum of the two does not 

exceed total permitted and non-permitted growth. If all of the ERCs used are 

pre-baseyear ERCs, there will be extremely little margin (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 setting 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 growth, 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 has not quantified the benefits of 

an off-road mobile agricultural equipment emission reduction measure. ARB 

staff plans to develop this emission reduction measure as part of the proposed 

State Strategy. Off-road mobile agricultural equipment currently accounts for 60 

tons per day of NOx emissions in the Valley. As older equipment turns over, 

these emissions are expected to decline to 34 tpd by 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 the 
May 30, 2007 19 

Valley, including where, when, and how this equipment operates. This 

understanding will improve the emissions inventory estimates and serve as the 

basis for a new emission reductions measure to be developed. 

(b) Non-point Source Industrial Natural Gas Combustion 

ARB staff recommends that the District explore opportunities 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 combustion of natural gas in non-point 

source industrial heaters, boilers, and burners resulted 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. Emissions from this category are 

expected to increase to more than 40 tpd NOx by 2023. 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 “gridded inventories” or 

“modeling inventories.” Even though the basic source of emissions data for 

planning and modeling purposes are the same, there are a variety of things that 

cause differences between emission estimates used for planning and modeling. 

Where air quality planning strategies are generally developed using seasonal 

emission estimates for air quality planning or political boundary regions, air 

quality models require hourly estimates of emissions for each grid cell in a 

modeling domain. In addition, because base year model simulations are 

required to meet specific performance criteria in the base year, the base year 

modeling inventory estimates must also be most representative of the actual 

emissions that occurred during the days and hours that are being simulated. The 

need for greater spatial and temporal resolution involves taking into 

consideration, for example, temperature effects on evaporative or biogenic 

emissions and emission upsets that might have occurred at large sources. 

During the July 30-August 2, 2000 base case, a large wildfire produced ozone 

precursors that affected air quality in the San Joaquin 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 – Industrial Natural Gas Combustion, available 

online at: 

http://www.valleyair.org/Air_Quality_Plans/EmissionsMethods/MethodForms/Mthd_IndustrialNGC

ombustion_SJV_2005.pdf 
May 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 simulate future air quality based 

on changes in emissions. Air quality modeling uses day-specific emission 

inventories, combined with meteorological and air quality measurements, to 

establish this relationship. The air quality modeling conducted for the Valley, as 

approved in the 2007 Ozone Plan, provides ROG to NOx carrying capacity 

diagrams which can be used to determine the relative efficacy of both ROG and 

NOx reductions. Rather than using air quality model 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 concentrations at a specific 

location (i.e. based on estimates of forecasted, future year emissions and baseyear emissions). The reference year for RRF calculations is 2002. The impact 

that future-year emission changes might have on reference-year pollutant design 

values is assumed to be proportional to the effect that the associated emission 

inputs used for modeling have on model-simulated concentrations. This is one of 

the reasons why multiple days are used in the calculation of RRFs, since the 

reference year design value is not day-specific. Thus, to estimate a future-year 

design value at a site, the 2002 reference-year, site-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 District, other northern California 

air districts, and the academic community. In particular, ARB staff drew heavily 

on the input and involvement of the CCOS Technical Committee, the Bay Area 

Modeling Advisory Committee, and the SIP Gridded Inventory Coordination 

Group. More information on the air quality modeling 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 selection of a modeling episode. The 

modeling episode is an actual time period(s), or base-case, where extensive 

information on emissions, meteorological conditions, and air quality data have 

been studied and which are representative of exceedance 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, 1999. Another episode in 

September 2000 was considered, but to date, model performance has been poor 

and consequently this episode has not been used. Episodes in 2000 were 

partially chosen because they fall within the intensive CCOS monitoring period 
May 30, 2007 21 

where a comprehensive data set to use in modeling is available. The 1999 

episode was chosen because the Bay Area and Sacramento Metropolitan Air 

Quality Management Districts believed ozone levels during that episode were 

representative of their concentrations. In addition to selecting the model, the 

CCOS Technical Committee and Northern California SIP/Transport working 

group considered and approved these episodes. 

For both the 1999 and 2000 episodes, the model-simulated ozone levels were 

near design values at key air monitoring sites. In general, modeling of these 

episodes met performance standards, but some concentrations were underpredicted at sites in the Valley. During the July – August 2000 episode, 

meteorology was generally representative of ozone exceedance days. A 

comparison of this episode to historical cases indicates that some days of the 

episode were extreme meteorological and pollutant events. For July 1999, 

statistical analyses also showed that meteorology was especially conducive to 

forming ozone. According to U.S. EPA guidance, these pollutant and 

meteorological characteristics make them good candidates for modeling. For 

these episodes, typical meteorological features that 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 been observed historically in 

Central California. Additional detail on the episode 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 Model with 

Extensions” (CAMx) modeling system was chosen to estimate the amount of 

emissions reductions needed to achieve the 8-hour ozone standard. 

A meteorological model, the Mesoscale Model version 5 (MM5), was used to 

generate the meteorological fields for the CAMx model. Modelers chose the 

[California] Statewide Air Pollution Research Center (SAPRC) chemical 

mechanism for the final run, which is slower computationally than other 

mechanisms but treats the chemical production of ozone 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 modeling conducted by ARB 

staff and includes a detailed model performance analysis. 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 July 1999 and 

July-August, 2000, episodes. The model performance evaluations are based on 

U.S. EPA guidance, as well as recommendations from published academic 
May 30, 2007 22 

literature. The model performance documentation also provides a summary of 

the performance analysis and provides a tabular listing 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) analysis 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. Appendix B of this staff report 

updates this analysis and summarizes the analyses that comprise the WOE 

assessment for the San Joaquin Valley nonattainment area. 

5. Attainment Emissions Target 

Air quality modeling helps to establish the attainment emission target, a key 

piece of information that policy-makers need in order 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 levels in the San Joaquin 

Valley are much more constrained by the availability of NOx, especially in the 

southern region. The air quality modeling indicates that NOx emissions must be 

reduced by 75 percent from current levels. Similarly, ROG emissions must be 

reduced nearly 25 percent. Greater ROG reductions would not substantially 

change the NOx reductions needed. For example, increasing the ROG 

reductions by an additional 50 percent would only decrease 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 establishing the attainment 

target. Table 6 shows the current emission levels, the attainment emission target 

used in the 2007 Ozone Plan, and the emission reductions which need to be 

achieved in order to attain the federal ozone standard. 

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 changes in emissions. The 

reactivity profiles for ROG species (i.e. the relative contribution of high vs. low 

reactivity ROG species) varies as new controls are implemented and older 

emission sources, primarily motor vehicles, are removed from service. However, 

reactivity and spatial changes tend to occur over a long time periods, so when 

the modeled years are close together chronologically, the impact of these 

changes is minimal. With that exception, carrying capacities can generally be 

viewed as independent of the year in which the absolute 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 quality 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 extreme non-attainment 

area SIP. Because the magnitude of the air quality challenge in the 

San Joaquin Valley, and the limits on existing emission control technologies, the 

San Joaquin Valley Unified Air Pollution Control District is left with only one 

federally approvable option: to request reclassification 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 extreme 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 aggressive, it does not provide 

all the NOx emission reductions needed for attainment in the Valley. ARB staff 

therefore performed a broad brush analysis to see whether the shortfall could be 

covered by assuming complete replacement of mobile source fleets with the 

cleanest new technology standards phasing in from 2007-2017. Cost was not a 

constraining factor in this analysis. ARB staff considered the constraints of legal 

authority, since SIP measures addressing sources not under our authority to 

control cannot be approved. 

In our analysis, shown in Table 7, we made the following assumptions: in 2020 

the Valley would have no passenger vehicles older than 10 years; all diesel 

trucks would meet the extremely stringent 2010 standards; 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 the 2007 Ozone Plan, as approved by the San 

Joaquin Valley Unified Air Pollution Control District on April 30, 2007. 

In the above table, the top four rows are italicized to indicate the categories for 

which we assume that all vehicles and equipment meets 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 from the standard emission 

inventory for 2020. Included in the category “all other NOx sources” are 

commercial gas trucks, motorcycles, buses, motor homes, ships and commercial 

boats, off-road recreational vehicles and gas powered 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 per day. Close to half of the 

remaining emissions, 103 tons per day, are from stationary and area-wide 

sources. Based on these types of analyses, long-term 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 2020 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 classification has impacts on 

industrial growth, it also allows the San Joaquin Valley to take advantage of the 

full suite of tools allowed by the Act, including the use of new emission control 

techniques which are expected to develop in the future. The impacts of 

reclassification are borne locally, so the decision to be reclassified is one which 
May 30, 2007 25 

should properly be made by the local air quality agency. The District Governing 

Board resolution adopting the 2007 Ozone Plan includes a request for U.S. EPA 

to reclassify the Valley to extreme nonattainment. 

E. Control Strategy 

Many actions already taken by the District, ARB, and U.S. EPA have reduced 

emissions in the San Joaquin Valley. These actions include the adoption of 

controls on stationary sources as well as reductions 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 Valley into attainment of the 

federal ozone standard. By 2023, ozone precursor emissions from on-road 

motor vehicles are expected to decline by nearly 70 percent, while off-road 

vehicles and equipment emissions will decline by more than 40 percent. 

Emissions from stationary and area sources are projected 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 deadlines established 

by U.S. EPA. ARB and District staffs have identified aggressive new emission 

control strategies which will result in marked improvement 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 reduction measures. Combined, 

the near-term strategies would provide significant additional emission reductions 

benefits. Table 8 illustrates the emission reductions 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 strategy provides enforceable 

measures and commitments that meet the applicable requirements for approval. 
May 30, 2007 26 

1. New Local Measures 

(a) Rule Development Commitment 

The San Joaquin Valley Unified Air Pollution Control 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 2012 ozone season and 8.2 tons 

per day by 2023. The 14 ROG emissions control rules will achieve reductions of 

26.5 tons per day and 46 tons per day by 2023. 

Table 9 lists the District’s emission reduction measure commitments, the 

emission benefits of these measures at each milestone year, and the rule 

adoption timelines as identified in Chapter Six of the District’s Plan. 
May 30, 2007 

Table 9 

Summary of the Near-term Rule Development Commitments* in the 2007 Ozone Plan 

(Summer Planning tons per day) 

Projected 

NOx Reductions by 20__ Year 

CM# 

Measure Name Product Completion Date Compliance Date Reduction Start 

08 11 12 14 17 20 23 08 11 

S-GOV-1 Composting Biosolids Rule 2007 1Q 2008 2008 2 3S-AGR-1 Open Burn Rule 2007 2Q 2010 2Q 2007 2010 2007 2010 1.1 2.4 2.4 2.4 3.5 3.5 3.4 1.3 2S-SOL-11 Solvents Rule 2007 3Q 2010 2010 0.0 1S-COM-5 Gas Turbines Rule 2007 3Q 2010 2010 0.0 0.6 0.6 0.61 0.64 0.66 0.68 S-IND-24 Soil Decontamination Rule 2007 3Q 2008 NA 0.0 0S-IND-6 Polystyrene Foam Rule 2007 3Q 2010 2011 0.0 0S-PET1&2 Gasoline Storage & Transfer Rule 2007 4Q 2009 2009 0.0 0S-PET-3 Aviation Fuel Storage Rule 2007 4Q 2010 2010 0.0 0.0S-COM-1 Large Boilers Rule 2008 3Q 2011 2011 0.0 0.0 0.69 0.72 0.75 0.77 0.8 S-COM-2 Medium Boilers

Incentives Rule Backstop 

2008 3Q 2020 2012 from incentives 0.0 0.0 0.51 0.51 0.51 0.51 0.51 

S-COM-7 Glass Melting Rule 2008 3Q Varies 2008 1.2 1.2 1.6 1.7 1.8 1.9 2.0 S-SOL-20 Graphic Arts Rule 2008 4Q 2011 2011 0.0 0S-COM-9 Residential Water Heaters Rule 2009 1Q Attrition 2011 0.0 0.2 0.25 0.40 0.55 0.70 0.85 S-GOV-5 Composting Green Waste Rule 2009 1Q 2012 2012 0.0 0S-IND-21 Flares Rule 2009 2Q NA NA 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0S-IND-14 Brandy & Wine Aging Rule 2009 3Q NA NA 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0S-SOL-1 Architectural Coatings Rule 2009 4Q 2012 2012 0.0 0

S-AGR-2 CAFO Rule 2010 2Q 2011 2011 0.0 6S-SOL-6 Adhesives Rule 2010 3Q 2012 2012 0.0 0

Total Projected 

NOx Reductions by 20__ Year 

08 11 12 14 17 20 23 08 11 

NA (Not Available) * For the purposes of implementing the 2007 Ozone Plan, the District is committed to adopt and implement control measures that will achieve, in aggregate, the emission reductions specified in Table 9. 2.3 4.4 6.0 6.3 7.8 8.0 8.2 3.3 15
May 30, 2007 28 

(b) Innovative Strategies 

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

could result in additional NOx and ROG reductions. These strategies include 

development of programs which will promote air quality friendly behavioral 

changes, including commitments to develop a green contracting “model 

ordinance,” to expand the Spare-the-Air efforts, to develop a heat-island 

mitigation model ordinance, and to promote alternative energy and energy 

efficiency within the Valley. The District will also explore ways to achieve even 

greater emission reductions from land development activities. 

The Valley Plan includes a commitment to explore the 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 District’s Rule 4901 “Wood 

Burning Fireplaces and Wood Burning Heaters.” This “check before you burn” 

program moves a step beyond informational “don’t light tonight” programs by 

prohibiting the use of wood-burning residential fireplaces when particulate matter 

levels are expected to be elevated. Episodic and regionally-focused controls will 

be considered as a part of each rule rulemaking exercise. The Valley Plan does 

not include quantified emission reduction commitment for these types of controls 

at this time. 

The Valley Plan also includes a commitment to consider amending other 

prohibitory rules to require facilities which are already subject to controls to 

achieve even greater emission reductions through the Advanced Emission 

Reduction Options (AERO) program. The AERO program would set emission 

reduction goals for stationary sources which are based on advanced 

technologies. 

The AERO program will be implemented through individual rulemaking efforts, at 

which time the appropriate level of advanced control goal would be determined. 

The AERO program is primarily a compliance flexibility tool, which will provide 

stationary source operators with flexibility to achieve additional emission 

reductions in a manner that fits into their individual 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 several possible options: 

application of the advanced controls upon which the regulation is based, 

achieving on- or off-site emission reductions by controlling other emission 

sources (such as replacing on-site forklifts), or through the payment of a fee to 

the District’s Community Clean Air Fund (CCAF). Funds placed into the CCAF 
May 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 employer-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 commutes, by making 

ridesharing or other mass transit options more appealing. Table 10 lists the 

emission benefits the District is committing to achieve 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-based 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 the 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 fees, and Department of 

Motor Vehicle Surcharge fees. Carl Moyer Program reductions are not credited 

here, as they are included in the ARB baseline adjustments 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 achieved through the Carl Moyer 

Program represent the “Gold Standard” for an incentive-based emission 

reduction program. When the District follows the Carl Moyer Program 

Guidelines, no additional effort should be needed to ensure that the emission 

reductions achieved are SIP creditable. The District staff is required to use the 

Carl Moyer Program Guidelines when expending funds from the Carl Moyer 

program. However, as the District addresses non-Carl Moyer Program funding, 

additional documentation may be necessary. The 2007 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 needed, the enhancement of 

auditing and enforcement of contracted emission reductions, and the tracking 

and periodic reporting of the benefits of the projects funded through the District’s 

incentive program. 

The District has the discretion to use the Carl Moyer Program Guidelines when 

expending funds from other sources. ARB staff encourages the District staff to 

use the protocols developed under the Carl Moyer Program Guidelines where 

applicable. However, recognizing that special circumstances 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 Moyer Program funds to 

address specific District needs. ARB staff will provide technical assistance in the 

development of these additional protocols, as needed. 

2. Proposed New State Measures 

Cleaning up the mobile NOx sources in the San Joaquin Valley is the most 

critical component of the emission control effort to reduce both ozone and PM2.5 

concentrations in the Valley. Vehicles and equipment operating in California are 

subject to the most stringent tailpipe emission standards in the world. ARB has a 

long history of adopting successful programs to reduce emission from mobile 

sources. These regulations will result in fewer emissions as vehicles and 

equipment units meeting the cleanest emission standards 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 use of engines meeting the 

cleanest emission control standards, ARB staff is proposing 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 staff’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 2023 in the San Joaquin Valley. 
May 30, 2007 31 

The potential emission reduction benefits of individual measures are provided for 

informational purposes only. The emission reduction benefits of the proposed 

State Strategy in 2014 will be considered, and recommended as a State 

commitment, in the context of the Valley’s PM2.5 attainment plan. Additional 

details on the individual measures being proposed by 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.htm 
May 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 Technology -- -- -- -- 

 Cleaner Main Ship Engines and Fuel -- -- -- -- 

 Port Truck Modernization -- -- -- -- 

 Accelerated Intro. of Cleaner Line-Haul Locomotives 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 Automotive Repair. DPR = Dept. of Pesticide Regulation 

Locomotives measure relies on U.S. EPA rulemaking and industry agreement to accelerate fleet turnover.

Note: Emission reductions reflect the combined impact of regulations and supportive incentive programs. 

Emission reduction estimates for each proposed measure are shown for informational purposes only. Actual 

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 include 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 has 
May 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 in California on an expedited 

timeline. U.S. EPA must work to develop these standards in a timeframe which 

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

4. Long-term Measures 

In order to attain the federal 8-hour ozone standard, the Valley needs to achieve 

a 75 percent reduction in NOx emissions and a 25 percent reduction in ROG 

emissions, valleywide. The near-term measure commitments in the 2007 Ozone 

Plan, as a whole, will reduce NOx emissions by 63 percent and ROG emissions 

by 25 percent. 

Combined, the near-term NOx emission reduction commitments adopted by the 

District and under consideration by ARB staff will not provide all of the NOx 

emission reductions necessary for the Valley to attain the federal ozone 

standard. Federal law 12 allows areas classified as extreme nonattainment of the 

federal ozone standard to take advantage of improvements in emission control 

technologies and techniques which are expected to develop in the future. This 

provision allows areas with the most extreme air quality challenges to develop 

approvable SIPs, even where 100 percent of the necessary reductions cannot be 

achieved cost effectively with today’s technologies. In order to demonstrate 

attainment, the 2007 Ozone Plan relies on the use of advanced technologies to 

achieve the last increment of emission reductions. 

More than 80 tons per day of the necessary NOx emission reductions remain to 

be achieved, beyond what known technologies will reliably achieve. It is 

impractical to presumptively apportion those reductions by primary regulatory 

authority. Both the ARB and District staffs must work diligently to identify and 

take advantage of all effective emission control technologies 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 promote the technologies and 

programs needed to achieve additional emission reductions 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 additional 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 regulatory implementation 

schedule to include those additional measures identified 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 measures 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 Incentives 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 quantifiable. FS reports will be released by the completion date, 

which may recommend an amendment to the Plan Regulatory 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 “beat-the-SIP” strategy is 

through the use of additional incentive monies. ARB staff supports use of 

incentives to accelerate the air quality progress. However, the federal regulation 

and policy constrains what can be included in a federally 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 District staff’s incentive-based 

emission reduction “action plan” which would be employed 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 implementing several emission 

reduction incentive programs, including the State funded Carl Moyer Program. 
May 30, 2007 36 

ARB staff believes that, where possible, District incentive funding should not be 

limited to mobile equipment. Where possible and cost effective, the District 

should explore funding ultra-clean stationary source technology. Funding the 

use of cutting-edge stationary source emission control technologies would help 

demonstrate that these technologies are effective in real-world applications. 

Development of these newer and more advanced technologies 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 reduction 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 quantifiable, surplus to 

regulatory requirements and inventory estimation assumptions, permanent over 

the life of the project, and enforceable by the District. Emission reductions 

meeting these requirements are considered to be “SIP creditable.” Identifying 

new funding streams, and implementing the requirement that emission 

reductions must be surplus to regulatory requirements, will help drive the 

development and implementation of new advanced technologies. 

Since prospective funding does not meet U.S. EPA SIP accountability criteria, 

the District plan does not take credit, in the attainment demonstration, for 

emission reductions achieved through prospective funding. However, once 

funding has been secured, the incentive measures identified will provide 

additional near-term emission reductions. Long-term, these will help achieve the 

last increment of emission reductions needed for attainment. As this money is 

secured, the District staff will work with the public, 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 programs. These sections were 

approved by the District and recognize the need to ensure that implementation of 

the publicly funded incentive programs is transparent. These sections will serve 

as the guiding principles and strategies the District staff will follow in developing 

new funding sources to support their beat-the-SIP approach. The District is not 

submitting sections 7.6 and 7.7 for inclusion in the San Joaquin Valley SIP. 
May 30, 2007 37 

(c) Long-term Concepts 

Chapter 11 of the 2007 Ozone Plan outlines three long-term strategy 

components: alternative energy sources, advanced retrofit/replacement 

technologies, and smart growth/land use. Developments in these three arenas 

could lead to increased emission reductions, reduced 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 include new technologies in 

their attainment plans. These attainment demonstration plans can rely on future 

advances in emission reduction technologies (referred to as new technologies) if 

the State, among other things: 

• submits enforceable commitments to develop and adopt contingency 

measures if the anticipated technologies do not achieve the planned 

reductions; 

• demonstrates that the contingency measures shall be adequate to 

produce emission reductions sufficient to achieve attainment and 

reasonable further progress. 

These contingency measures to back-up the new technology provisions are not 

due until three years before implementation of these new technology provisions. 

After adoption of the State Strategy, ARB staff proposes 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 process to assess technology 

advancement opportunities for the critical categories. ARB staff will periodically 

brief the Board at public meetings on emerging emission reduction opportunities, 

promising technologies, and the progress made in developing long-term emission 

reduction measures. As ARB staff identifies feasible technology-forcing emission 

reduction measures, staff will propose those measures to the Board for inclusion 

into the SIP. 

No later than 2020, ARB and the District will prepare a revision to the 8-hour 

Ozone SIP that (1) reflects any modifications to the 2023 emission reduction 

target based on updated science, and (2) identifies any additional strategies, 
May 30, 2007 38 

including the implementing agencies, needed to achieve the necessary 

emissions reductions by 2023. If the specific measures developed to satisfy the 

long-term obligation affect on-road motor vehicle emissions, 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 previously, including long-term 

measures, will provide the necessary emission reductions to demonstrate 

attainment of the federal standard by 2023. Table 14 demonstrates that the 

required emission reductions will be achieved by implementing the commitments 

for new and long-term measures proposed in the State 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 355 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 technology 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 2020 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 Applicable 

Deadline 

The Act requires that, should the Valley not attain the federal 8-hour zone 

standard by 2024, the SIP include contingency measures 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 after the Valley’s attainment 

deadline. Those additional benefits achieved are available to meet the 

attainment-year contingency requirements. ARB staff is proposing to commit the 

benefit of the State’s mobile source emission reduction program in 2024 for 

attainment-year contingency measures. 

The Act also requires that areas classified as severe or extreme nonattainment of 

the federal ozone standard include In the SIP procedures to levy a fee for failure 

to attain.14 The District has an adopted a rule15 implementing these 

 

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

14 Section 185 of the 1990 Clean Air Act Amendments. 

15 San Joaquin Valley Unified Air Pollution Control District 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 Measures 

The Clean Air Act requires that areas classified moderate or greater, 

demonstrate that progress towards attaining the federal standard will not be 

delayed. This Reasonable Further Progress (RFP) requirement ensures that 

areas do not delay implementation of emission control programs until 

immediately before the attainment date. RFP requirements 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 average, an additional 3 percent 

per year reduction in ROG and/or NOx emissions until their attainment year. 

The Act also requires that nonattainment areas provide for contingency 

measures which take effect without further action if an area fails to achieve the 

reductions required to demonstrate RFP. U.S. EPA has 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, demonstrates that all of the 

emission reductions needed to meet the RFP and progress related contingency 

measure requirements will come from the existing emission control program. 

ARB staff concurs that RFP and contingency measures requirements are met 

through currently adopted rules and regulations. Table 15 sets out the RFP and 

contingency measure demonstration conducted by ARB staff. This 

demonstration includes the impacts of the revised pesticide emissions, which 

were not available in time for inclusion in the publication and adoption of the 

2007 Ozone Plan by the District. As such, ARB staff is proposing to submit this 

RFP demonstration to U.S. EPA for inclusion in California’s SIP for the San 

Joaquin Valley. Details on the calculation procedures can be found in 

Appendix D to the proposed State Strategy, and is available on-line at: 

 http://www.arb.ca.gov/planning/sip/2007sip/apr07draft/revdrftappd.pdf 
May 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-level on-road motor vehicle 

emission transportation conformity budgets for each milestone year, as well as 

for the attainment year. The emissions budgets reflect the latest planning 

assumptions and were developed using EMFAC2007. These new conformity 

budgets are listed in Table 16. Detailed calculations used to derive the 

transportation conformity budgets can be found in Chapter 9 and Appendix C of 

the San Joaquin Valley 2007 Ozone Plan. 

Two updates to the San Joaquin Valley on-road transportation conformity 

budgets are being proposed by ARB staff: new on-road 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 San Joaquin County 

transportation conformity budgets for 2008 to fix a data input error discovered 

subsequent to District Governing Board action. Table 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 emission budgets established in 

the Valley’s 2007 Ozone Plan fulfill the requirements 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 standard. 

Table 16 

Transportation Conformity Budgets a

(Summer planning tons per day) 

County 2008 2011 2014 2017 2020 2023 

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 established by taking the EMFAC results, subtracting by 

County, emission reductions from District and ARB control measures and rounding up to the nearest tenth if 

the hundredths place was “1” or higher. 

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

I. Additional Requirements for Extreme Nonattainment Areas 

1. Major Source Permitting Requirements 

The Act requires that areas classified as extreme nonattainment revise their 

permitting requirements to be applicable to sources with the potential to emit 

10 tons per year of ozone forming emissions. The 2007 Ozone Plan includes a 

commitment to submit to U.S. EPA a revised New Source 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 Ozone 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 commercial boilers which emit more than 

25 tons per year of NOx. Existing District rules 16 meet implement this 

requirement. More information is available in Chapter 2 of the Valley’s 2007 

Ozone Plan. 

 

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

IV. ENVIRONMENTAL IMPACTS 

The California Environmental Quality Act (CEQA) requires that State and local 

agency projects be assessed for potential significant environmental impacts. Air 

quality plans are “projects” that are potentially subject to CEQA requirements. 

The District staff found that the plan would not have a significant effect on the 

environment and prepared an Initial Study/Negative Declaration. The District 

Governing Board approved this Initial Study/Negative Declaration on 

April 30, 2007.17

V. LEGAL AUTHORITY 

The federal Clean Air Act Amendments (the Act) require states to provide for the 

attainment of national ambient air quality standards. The primary tool to be used 

in the effort to attain national ambient air quality 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 110(a)(2)(A) of the Act broadly 

authorizes and directs states to include in their SIPs: 

"...enforceable emission limitations and other control measures, means, or 

techniques (including economic incentives such as fees, marketable permits, and 

auctions of emissions rights), as well as schedules and timetables for 

compliance, as may be necessary or appropriate to meet 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 control agency for all purposes 

set forth in federal law. 

The state board is designated as the state agency responsible for the preparation 

of the state implementation plan required by the Clean Air Act (42 U.S.C., Sec. 

7401, et seq.) and, to this end, shall coordinate the 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 division, 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 District resolution number 07-04-11a. 
May 30, 2007 45 

ARB will exclude from the SIP submittal any provisions of the San Joaquin 

Valley 2007 Ozone Plan that relate solely to the California 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 extensively 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 implementation 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 following actions: 

(1) Adopt the local elements of the 2007 San Joaquin Valley 2007 Ozone 

Plan as a revision to the California SIP, including the local control strategy, 

the updated emission inventories, the updated attainment demonstration, 

and the updated motor vehicle emission budgets. 

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

as a revision to the California SIP. 

The San Joaquin Valley 2007 Ozone Plan relies on emission reductions to be 

achieved from the proposed State Strategy for California’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 considering the 2007 Ozone Plan 

before the State Strategy has been approved. Therefore, final ARB action on the 

San Joaquin Valley’s 2007 Ozone Plan would be contingent upon ARB’s 

subsequent adoption of commitments, as part of the State Strategy, to achieve 

the emission reductions from State measures.