SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E: Cost Effectiveness Analysis for Rules 9510 and 3180 December 15, 2005

Final Draft Staff Report for Proposed

 Rule 9510 and Rule 3180

E - 1

APPENDIX E

Cost Effectiveness Analysis for Proposed

Rule 9510 (Indirect Source Review) and

Rule 3180 (Administrative Fees for Indirect Source Review)

December 15, 2005
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E: Cost Effectiveness Analysis for Rules 9510 and 3180 December 15, 2005

Final Draft Staff Report for Proposed

 Rule 9510 and Rule 3180

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I. INTRODUCTION

California Health and Safety Code (CH&SC) Section 40920.6(a) requires the San 

Joaquin Valley Unified Air Pollution Control District (District) to conduct a cost 

effectiveness analysis of the proposed control options prior to the adoption of the 

proposed rules. The purpose of conducting a cost effectiveness analysis is the 

evaluation of the possible economic effect of the pollution control measures (rules). The 

analysis also serves a guideline in developing the control requirements for the rule.

II. SUMMARY AND CONCLUSION

The CH&SC section cited above requires a cost effectiveness analysis for the most 

likely compliance scenario, and an incremental cost effectiveness analysis on an 

alternative compliance scenario. Absolute cost effectiveness of a control option for 

traditional rules are typically determined by taking the added annual cost (in $/year) of 

the control technology or technique, divided by the emission reduction achieved (in 

tons/year). The costs can include capital equipment costs, engineering design costs, 

installation costs, and any cost savings, such as from decreased energy usage and 

decreased maintenance costs. 

Rule 9510 would require developers to reduce the following project’s operational and 

area source emissions: 33.3% of NOx emissions and 50% of the PM10 emissions, over 

a ten-year period. Rule 9510 would also require the developers to reduce emissions 

from equipment used during the construction phase by 20% for NOx and 45% for PM10 

emissions compared to the statewide average. The construction emissions may be 

reduced on-site by using newer fleets than the statewide construction average, using 

add-on controls, and/or by using clean fuels. The rules are structured to allow flexibility 

in complying with the rule requirements due to various requirements and limitations 

imposed by local agencies in the projects’ jurisdiction. Methods of compliance include 

the following: achieving the necessary reductions entirely through on-site emission 

reduction measures; reducing, in varying degrees, partially on-site and partially off-site 

through the off-site emission reduction fee; reducing entirely off-site through the 

payment of an off-site emission reduction fee. The fee for emissions not reduced in the 

design of the project or with equipment controls would fund off-site emission reduction

projects. The fee for these off-site projects would be calculated by multiplying the 

required emission reductions by a cost effectiveness factor. This rule differs from 

traditional rules, in that a cost effectiveness value is predetermined and the control 

costs are based on that cost effectiveness value. 

Cost effectiveness is a primary criterion for the District to fund emission reduction 

projects. Cost effectiveness of a off-site emission reduction project is based on the 

amount of pollution (per pound or ton of a pollutant) the project eliminates for each 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E: Cost Effectiveness Analysis for Rules 9510 and 3180 December 15, 2005

Final Draft Staff Report for Proposed

 Rule 9510 and Rule 3180

E - 3

dollar spent. There are different methodologies to determine cost effectiveness for 

different programs, but in general, cost effectiveness is determined by dividing the cost 

of the project by the amount of emissions reduced. Several factors are used to 

determine the emission reductions for a particular mitigation project, including: the age 

of the vehicle or engine being replaced, project life (how long in terms of time the 

emission reductions can be expected to be surplus), and activity level, which is usually 

represented in annual hours of operation or mileage. Project life allows the District to 

determine how many emission reductions can occur per year. This is important in 

determining timelines for emission reductions and will assist the District in attaining the 

ozone and PM10 standards. 

To determine the cost effectiveness for the ISR Program, District staff identified NOx 

emission reduction projects that have previously been funded and the costs associated 

with each project. Table E–1, Estimated NOx Emission Reductions from Current and 

Historical Grant Programs by the District summarizes the grant programs. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E: Cost Effectiveness Analysis for Rules 9510 and 3180 December 15, 2005

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E - 4

Table E-1

Estimated NOx Emission Reductions from Current and Historical Grant Programs

Emissions Emissions Grant Funded

Cost 

Effectiveness*

Cost 

Effectiveness*

Tons Pounds

Dollar 

Amounts $/Pound $/Ton

All External Projects

1992 -1993 400 800,000 $3,665,200 $4.58 $9,163.00 

1993 -1994 525 1,050,000 $4,773,814 $4.55 $9,092.98 

1994 - 1995 590 1,180,000 $3,594,486 $3.05 $6,092.35 

1995 - 1996 650 1,300,000 $3,688,311 $2.84 $5,674.32 

1996 - 1998 885 1,770,000 $6,309,952 $3.56 $7,129.89 

1998 - 2004 30,419 60,838,805 $60,798,609 $1.00 $1,998.68 

Total 33,469 66,938,805 $82,830,372 $3.26 $6,525.20 

REMOVE Program

1992 - 1993 Phase I 400 800,000 $3,665,200 $4.58 $9,163.00 

1993 - 1994 Phase II 525 1,050,000 $4,773,814 $4.55 $9,092.98 

1994 - 1995 Phase III 590 1,180,000 $3,594,486 $3.05 $6,092.35 

1995 - 1996 Phase IV 325 650,000 $2,688,311 $4.14 $8,271.73 

1996 - 1998 Phase V 360 720,000 $5,309,952 $7.37 $14,749.87 

1998 - 1999 Phase VI 104 208,247 $2,556,403 $12.28 $24,551.64 

1999 - 2000 Phase VII 304 607,640 $2,422,741 $3.99 $7,974.26 

2002 - 2003 Phase VIII 156 311,059 $1,210,648 $3.89 $7,784.04 

Total 2,608 5,526,946 $26,221,555 $5.48 $10,959.98 

Vehicle Buy-Back

1995 - 1996 325 650,000 $1,000,000 $1.54 $3,076.92 

1997 - 1998 525 1,050,000 $1,000,000 $0.95 $1,904.76 

Total 850 1,700,000 $2,000,000 $1.25 $2,490.84 

Heavy-Duty Program

1997 - Jan 2004 29,811 59,622,859 $53,381,817 $2.28 $4,564.13 

Lt. & Med.-Duty Vehicle Program

2001 - Jan 2003 22 43,000 $750,000 $17.44 $34,883.72 

1999 Lawnmower Replacement Program

2001 - 2002 23 46,000 $477,000 $10.37 $20,739.13 

Please note that beginning in 1995-96 vehicle buy-back was no longer included in the REMOVE Program.

A separate program for heavy-duty vehicle projects was established beginning in 1997.
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E: Cost Effectiveness Analysis for Rules 9510 and 3180 December 15, 2005

Final Draft Staff Report for Proposed

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III. GRANT PROGRAMS

This section identifies the existing grant programs and different types of projects that are 

funded under those programs that are possible candidates for any off-site emission 

reduction fees collected under Rule 9510. In addition, this section identifies additional 

projects that may be funded through the ISR program. The District will also consider 

projects and programs for funding in addition to the ones discussed in this section, when 

other projects and programs are identified. 

REMOVE/REMOVE II

The Reduce Motor Vehicle Emissions (REMOVE) Program was the first District grant 

program implemented in 1992 to fund projects that reduced emissions associated with 

motor vehicle trips. Due to the lengthy REMOVE evaluation committee process, the 

District’s Governing Board approved the revised REMOVE II Program on March 13, 2005. 

The REMOVE II Program awards grant funding on a first-come, first-serve basis and 

consists of a broad range of mobile source incentive projects. The following separate 

components within the REMOVE II Program have established parameters and funding 

caps to achieve prudent cost effectiveness levels: E-Mobility (Telecommunications) 

Incentive Component; Public Transportation and Commuter Vanpool Passenger Subsidy 

Component Bicycle Infrastructure Component; Light and Medium Duty Incentive 

Component. The components establish guidelines to maximize the emission reduction 

potential for individual projects. The criterion for evaluating potential projects is ARB’s 

methodology for calculating cost effectiveness and emission reductions. Additionally, the 

District has established requirements for applicants to validate the emission reductions 

generated by REMOVE II incentive program components.

The E-Mobility Component of the REMOVE II Program provides funding for the 

development or expansion of electronic telecommunications services in municipal 

government and public education. The electronic technology will serve as direct 

replacement of vehicle trips to public sites for conferencing, document transactions, 

general information, work functions, school instruction, and related applications. E-Mobility 

projects include: distance-learning technology, telecommute center equipment, 

teleconference systems, E-government technology, E-court technology and related 

electronic applications.

The Public Transportation and Commuter Vanpool Passenger Subsidy Component of the 

REMOVE II Program, provides funding to attract new participants to public transportation 

and commuter vanpools. The passenger subsidies will serve to attract new participants to 

public transportation and commuter vanpools as an alternative to single occupant vehicle 

(SOV) commutes. Passenger subsidy projects include: incentives for transit bus agencies, 

shuttles, commuter vanpools, rail, and park-and-ride lot construction.

The Bicycle Infrastructure Component of the REMOVE II Program will fund the 

development of a comprehensive bicycle transportation network. The component will 
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Appendix E: Cost Effectiveness Analysis for Rules 9510 and 3180 December 15, 2005

Final Draft Staff Report for Proposed

 Rule 9510 and Rule 3180

E - 6

support the expansion and linkage of bicycle transportation facilities that promotes the 

practice of commuter bicycling as a safe and viable transportation alternative. 

Bicycle infrastructure projects may include the development of Class I Bicycle Paths 

(construction) and Class II Bicycle Lanes (striping). 

The Light and Medium Duty Incentive Component of the REMOVE II Program will fund a 

portion of the purchase cost of low-emission light-duty and medium-duty motor vehicles for 

public agencies. The purpose for the component is to encourage and increase the 

introduction of reduced emission alternative fuel vehicles. Low-emission vehicles may 

include Zero Emission Vehicles, Super Ultra Low Emission Vehicles, Ultra Low Emission 

Vehicles, and Electric Bicycles based on ARB emission standards.

Heavy-Duty Program

The Heavy-Duty Engine Emission Reduction Incentive Program (Heavy-Duty Program) 

initially evolved from REMOVE in 1997 and the District continues to administer the 

program. The Heavy-Duty Program replaces older model high polluting engines with 

newer and cleaner burning engines. The Heavy-Duty Program also encourages the early 

introduction of on-road and off-road heavy-duty motor vehicles with engines that include 

reduced-emission technologies. Eligible project types funded under this program include: 

marine vessels, forklifts, agricultural pump engines, on-road and off road vehicles and 

equipment, agricultural harvesters, hay bailers, tractors, delivery trucks, sprayers, yard 

spotters, earthmovers, line haul trucks, back hoes, dump trucks, earth movers and drills, 

transit and school buses, and forklifts. This program has been expanded to assist in the 

development of alternative fuel infrastructure, particulate filters on eligible diesel school 

buses, and idle reduction technologies for heavy-duty vehicles.

Emission reductions are obtained when the project applicant purchases vehicles and 

engines that are cleaner than required by current emission standards or installs an 

emission certified retrofit kit on an existing engine. The District pays the differential cost of 

purchasing the lower emitting technology compared to conventional technology. Emission 

reduction, calculations, and horsepower categories are used to determine an incentive 

amount. Project monitoring is conducted to verify eligibility, to ensure proper use of public 

funds and to validate the emission reductions. Applicants are required to enter 

into contracts with the District and are required to submit annual usage reports for five 

years after the technology is purchased. 

The Heavy Duty Program is primarily aimed at NOx reductions, but many projects also 

achieve particulate matter (PM10) reductions. Historically, this incentive program has 

been exceptionally cost effective, replacing approximately 4,484 engines1. 

 

1

 SJVAPCD Heavy-Duty Engine Incentive Program Database
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E: Cost Effectiveness Analysis for Rules 9510 and 3180 December 15, 2005

Final Draft Staff Report for Proposed

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PM10 Incentive Program

The District currently does not have an incentive program that primarily targets PM10 

emissions reductions, however an incentive program will be needed for Rule 9510. 

Initially, District staff surveyed the PM10 emissions inventory to determine the largest 

sources of emissions and related factors, the extent of existing or planned control, and 

types of control options that are available. District staff identified unpaved traffic 

surfaces and unpaved shoulders as the most viable options for emission reduction 

projects. Other potential sources include the use of PM10-efficient street sweepers and 

fireplace retrofits/replacement. The District is proposing to develop an Unpaved Road 

and Traffic Surface Program that would fund or partially fund the treating or paving of 

unpaved roads or unpaved shoulders within the San Joaquin Valley Air Basin, in time to 

implement and achieve the reductions committed to for this rule. Once that program is 

established, the District will continue to explore and develop other PM10 incentive 

programs, such as PM10-efficient street sweepers, fireplace retrofits/replacement, 

and/or leaf blowers.

The duration of the contract will vary depending on the project. Some contracts will be 

completed upon installation, while others may require reporting for 5 years. For

example, a road-paving project would have a contract that is completed upon

installation, whereas an engine contract typically contains a 5-year reporting

requirement. The staff report will be amended to include this information.

IV. RULE 9510 ESTIMATED COST EFFECTIVENESS

The District’s future prospects for funding the most cost effective NOx reduction projects 

are currently declining. Many of engines that qualify for the Heavy-Duty Program 

incentive funds have been replaced or retrofitted. Diesel engines greater then 50 

horsepower are being regulated by the State and the District resulting in cleaner 

operating engines with lower emissions. Consequently, the most cost-effective projects 

(e.g. diesel engines manufactured before 1996) have previously been funded resulting 

in projects that will cost more in the future to fund.

To determine future cost effectiveness for NOx emission reduction projects, staff 

reviewed previously funded projects’ NOx cost effectiveness, the types of projects, and 

the future availability of those projects. Attachment 1 compiles the necessary 

information and determines the resulting cost effectiveness. The general concept for 

NOx projects in Attachment 1, is that the types of grant applications received will move 

from the heavy duty projects to lighter duty projects at a rate of 5% per year, and that 

the cost of heavy duty projects will increase approximately $2000 more per ton. 

Attachment 1, can be summarized as follows:
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Appendix E: Cost Effectiveness Analysis for Rules 9510 and 3180 December 15, 2005

Final Draft Staff Report for Proposed

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NOx Cost-Effectiveness 

Year Cost to Reduce 

One ton of NOx

2006 $4,650.00

2007 $7,100.00

2008 and 

beyond

$9,350.00

Presently, most of the Districts incentive funds have been used to fund NOx emission 

reductions. In order to determine future cost effectiveness for PM10 emission reduction 

projects, District staff researched PM10 emissions and reductions. Initially, the PM10 

emissions inventory was surveyed to determine the largest sources of emission factors, 

the extent of existing or planned control, and types of control options that are available. 

District staff identified unpaved traffic surfaces and unpaved shoulders as the most 

viable options for emission reduction projects. Other potential sources include the use 

of PM10-efficient street sweepers and fireplace retrofits/replacement. 

Once the sources were identified, each source was analyzed in terms of emission 

factors, thresholds, available control effectiveness, and costs of those controls. 

Attachment 1 also compiles the necessary information and determines the resulting cost 

effectiveness for PM10 projects. There are several concepts for PM10 projects that are 

incorporated in Attachment 1. Initially, the District is anticipating that it will receive a 

high number of applications to treat or pave unpaved roads, with the most cost effective 

projects coming in the first few years. The District is also expecting the cost to treat or 

pave unpaved roads to increase by 75% each year for each ton reduced. The District is 

anticipating receiving a higher number of applications for unpaved shoulders and street 

sweepers, each year. Attachment 1, can be summarized as follows for PM10:

PM10 Cost-Effectiveness 

Year Cost to Reduce 

One ton of PM10

2006 $2,907.00

2007 $5,594.00

2008 and 

beyond

$9,011.00

V. SOURCES OF COST DATA

District staff used cost effectiveness information derived from actual NOx emissions 

reduction projects administered by the District. This data is sent to the California Air 
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Appendix E: Cost Effectiveness Analysis for Rules 9510 and 3180 December 15, 2005

Final Draft Staff Report for Proposed

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Resources Board (ARB) on an annual basis. The following data sources were used for 

the PM10 analysis:

1. Effectiveness Demonstration of Fugitive Dust Control Methods for Unpaved Roads 

and Unpaved Shoulders on Paved Roads

DRI document No. 685-5200.1F1

Desert Research Institute 

December 31, 1996

2. Methods to find Cost-effectiveness of Funding Air Quality Projects: For Evaluating 

Motor Vehicle Registration Fee Projects and Congestion Mitigation and Air Quality 

Improvement (CMAQ) Projects

California Air Resources Board 

2003 Edition

3. Final BACM Technological and Economic Feasibility Analysis

Sierra Research, Inc. 

Prepared for the SJVAPCD

March 2003

4. Entrained Road Dust from Paved Road Travel: Emission Estimation Methodology, 

Background Document

Section 7.9

California Air Resources Board 

Updated July 1997

5. Unpaved Road Dust (non-farm roads, SJV only)

Section 7.10 SJV

California Air Resources Board

Patrick Gaffney

Updated May 2004

6. Spreadsheet used for San Joaquin Valley Air Pollution Control District PM10 SIP, 

2003

Spreadsheet, “Unpaved1999Mar_13_2003Final.xls”

California Air Resources Board

Patrick Gaffney

7. Conversations and E-mail correspondence with Mel Zeldin, consultant
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Appendix E: Cost Effectiveness Analysis for Rules 9510 and 3180 December 15, 2005

Final Draft Staff Report for Proposed

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E - 10

Attachment 1

Anticipated Use of ISR Funds

for Determining Cost Effectiveness

For 2006

Cost Effectiveness ($/ton reduced)

Projected % of 

Fund Use Likely 

Minimum Cap1

Representative 

Cost 

Effectiveness2

Weighted 

Representative 

Factor

PM10

Unpaved Roads/Traffic 

Areas 90% $1,694 $15,000 $1,819

Unpaved Shoulders 5% $11,838 $15,000 $12,907

Street Sweepers 5% $10,000 $15,000 $12,500

Overall PM10 $1,694 $15,000 $9,075 $ 2,907 

NOx

Heavy Duty Program 95% $3,000 $5,000 $4,000

REMOVE 5% $14,000 $20,000 $17,000

Overall NOx $3,000 $20,000 $10,500 $ 4,650 

For 2007

Cost Effectiveness ($/ton reduced)

Projected % of 

Fund Use Likely 

Minimum Cap1

Representative 

Cost 

Effectiveness2

Weighted 

Representative 

Factor

PM10

Unpaved Roads/Traffic 

Areas 75% $1,900 $15,000 $3,183

Unpaved Shoulders 20% $11,838 $15,000 $12,907

Street Sweepers 5% $10,000 $15,000 $12,500

Overall PM10 $1,900 $15,000 $9,530 $ 5,594 

NOx

Heavy Duty Program 90% $5,000 $7,000 $6,000

REMOVE 10% $14,000 $20,000 $17,000

Overall NOx $5,000 $20,000 $11,500 $ 7,100 
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Appendix E: Cost Effectiveness Analysis for Rules 9510 and 3180 December 15, 2005

Final Draft Staff Report for Proposed

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Anticipated Use of ISR Funds

for Determining Cost Effectiveness

For 2008

Cost Effectiveness ($/ton reduced)

Projected % of 

Fund Use Likely 

Minimum Cap1

Representative 

Cost 

Effectiveness2

Weighted 

Representative 

Factor

PM10

Unpaved Roads/Traffic 

Areas 55% $1,900 $15,000 $5,571

Unpaved Shoulders 35% $11,838 $15,000 $13,419

Street Sweepers 10% $10,000 $15,000 $12,500

Overall PM10 $1,900 $15,000 $10,497 $ 9,011 

NOx

Heavy Duty Program 85% $7,000 $9,000 $8,000

REMOVE 15% $14,000 $20,000 $17,000

Overall NOx $7,000 $20,000 $12,500 $ 9,350 

For 2009

Cost Effectiveness ($/ton reduced)

Projected % of 

Fund Use Likely 

Minimum Cap1

Representative 

Cost 

Effectiveness2

Weighted 

Representative 

Factor

PM10

Unpaved Roads/Traffic 

Areas 55% $1,900 $15,000 $9,749

Unpaved Shoulders 35% $11,838 $15,000 $13,419

Street Sweepers 10% $10,000 $15,000 $12,500

Overall PM10 $1,900 $15,000 $11,889 $ 11,308 

NOx

Heavy Duty Program 80% $9,000 $12,000 $10,500

REMOVE 20% $14,000 $20,000 $17,000

Overall NOx $9,000 $20,000 $13,750 $ 11,800 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E: Cost Effectiveness Analysis for Rules 9510 and 3180 December 15, 2005

Final Draft Staff Report for Proposed

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E - 12

Anticipated Use of ISR Funds

for Determining Cost Effectiveness

For 2010

Cost Effectiveness ($/ton reduced)

Projected % of 

Fund Use Likely 

Minimum Cap1

Representative 

Cost 

Effectiveness2

Weighted 

Representative 

Factor

PM10

Unpaved Roads/Traffic 

Areas 45% $1,900 $15,000 $14,682

Unpaved Shoulders 40% $11,838 $15,000 $13,419

Street Sweepers 15% $10,000 $15,000 $12,500

Overall PM10 $1,900 $15,000 $13,534 $ 13,850 

NOx

Heavy Duty Program 75% $11,000 $13,000 $12,000

REMOVE 25% $14,000 $20,000 $17,000

Overall NOx $11,000 $20,000 $14,500 $ 13,250 

1 The cost effectiveness cap in this column represents the cap that this program would require, not necessarily the historical cap.

2 The representative cost effectiveness is the anticipated cost effectiveness for that year. This is based on district staff forecast.
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E – Attachment 1: ISR Spending Plan December 15, 2005

Final Draft Staff Report for Proposed

 Rule 9510 and Rule 3180

E - 13

APPENDIX E

Attachment 1

Project Spending Plan for Proposed

Rule 9510 (Indirect Source Review)

December 15, 2005
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E – Attachment 1: ISR Spending Plan December 15, 2005

Final Draft Staff Report for Proposed

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I. INTRODUCTION

The purpose of this document is to demonstrate that any funds collected by the District 

will meet their intended purpose of reducing emissions caused by new development in 

the air basin. It provides a plan for spending any funds generated by the rule in a costeffective and responsible manner.

Rule 9510 is projected to generate up to $103 million between 2006 and 2008. After 

2008 the District will provide a new estimate based on experience with the program and 

the amount of development occurring in the San Joaquin Valley. The new estimates 

may be higher or lower than the amounts currently in the rule. To demonstrate the 

capability to distribute these funds to cost-effective projects, the District has analyzed 

the potential emission reduction projects available that meet requirements for being 

surplus, quantifiable, and enforceable. Once the potential projects were identified, staff 

performed additional research into the cost of individual projects and the potential for 

owners of the equipment, vehicles, etc. to take advantage of incentive funding. 

The District plans on using existing grant programs that are available for immediate 

funding of projects and to develop new programs for non-traditional sources not eligible 

for other funding sources such as DMV Surcharge Fees and California Carl Moyer 

Program funds.

II. Existing Programs

The following existing programs and programs where the District has operated 

programs in the past are described in Appendix E.

• Heavy-Duty Engine Incentive Program

• REMOVE II Program

• Lawnmower Buyback Program

• Light and Medium Duty Vehicle Program

• Voluntary Accelerated Vehicle Retirement

The Heavy-Duty Engine Incentive Program and REMOVE II Program are currently in 

operation and can be used as an outlet for funds from ISR immediately. Other 

programs where the District has past experience can be implemented quickly.
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Appendix E – Attachment 1: ISR Spending Plan December 15, 2005

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III. New Programs

Stationary Source Incentive Program

Program concept: Some control options that are in excess of current rule requirements 

and best available control technology (BACT) thresholds can be implemented with the 

help of incentive funding. These options typically exceed BACT cost-effectiveness 

limits or were not required by the rule due to economic impacts; however, relatively 

cost-effective control options may be available in a variety of industries. 

All projects would be required to demonstrate that they are:

• Surplus to all federal, state, and local requirements

• Quantifiable – emission reductions can be determined

• Enforceable – a mechanism is available to ensure that reductions occur

• Permanent – reductions are maintained for the life of the credit

There are several potential ways in which stationary source operators would be 

attracted to the incentive program:

• Applicant initiated - Applicant proposing expansion or equipment replacement 

approaches the District with equipment or control technologies in excess of 

requirements.

• District initiated - District permit engineers identify control technology in excess of 

BACT requirements and rule requirements during project review and suggest to 

applicant the potential for going beyond requirements with the help of incentive 

funding.

• Ongoing program - The District identifies specific equipment or technologies in 

excess of requirements in a grant program and open application process. 

Stationary Source Project Review Process Outline:

1. For projects identified during BACT analysis required under Rule 2201, permit 

engineers identify potential control technology that exceeds BACT requirements 

and is surplus of all regulations.

2. The engineer contacts Emission Reduction Incentive Program (ERIP) staff to 

forward cost effectiveness analysis. Note: the cost effectiveness performed for 

ERIP purposes is not the BACT cost effectiveness.

3. ERIP determines whether project meets ISR funding criteria and contacts PSD 

and applicant.

4. If not, the project, as initially proposed, is processed by Permit Staff.

5. If yes, 3-parts meeting (ERIP, PSD, Applicant) to review feasible options 

(technical aspects and funding).
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6. Project, as initially proposed, is on hold, waiting for ERIP and applicant final 

approval/decision.

7. Applicant determines whether the project would be feasible at their facility.

8. If not, the project, as initially proposed, is processed by Permit Staff.

9. If yes, ERIP staff initiates incentive funding application process.

10.For eligible projects, the applicant would complete an application providing 

contact information and complete project and cost information.

11.Initial project amended to incorporate new proposed control technology.

12.The application would be approved by ERIP and Permit Service Division (PSD).

13.ERIP staff would prepare a contract for the project between the applicant and the 

District.

14.PSD would incorporate the new controls and emission amounts into the 

applicant’s permit application.

15.PSD issues an Authority to Construct (ATC) allowing the applicant to install the 

new control.

16.Compliance staff conducts an inspection, that may include a source test for some 

projects, to verify the emission reductions.

17.Compliance notifies PSD and ERIP that the installation is complete.

18.ERIP approves claim for payment for the contract.

19.Finance issues payment for the project to the applicant.

20.Long term monitoring and reporting is accomplished through the normal process 

for permitted equipment.

21.ERIP reports emission reductions in periodic reports to the Governing Board.

Projects may also enter the system that are initiated by operators of the permitted 

sources. In these cases, PSD will conduct an assessment to determine technological 

feasibility and if the project is surplus and enforceable. PSD would then turn the project 

over to ERIP for application processing and contracting. Project types that have the 

potential for large numbers of applications may become an ongoing program 

component with outreach to recruit applicants.

Example Projects

The following are examples of projects that illustrate the potential to obtain emission 

reductions through a stationary source incentive program. All projects listed would 

require additional research and analysis prior to offering incentives.

Example: Replace natural gas fired boilers/burners with cleaner model.

Under District Rule 4306, boilers rated from greater than 5 up to 20 MMBTU per hour 

are required to achieve a NOx emission rate of 15 ppm. If the applicant currently 

operated a 30 ppm boiler, when it comes time to replace the boiler, he would be 

required to install a 15 ppm boiler. Due to advances in technology there are now 9 ppm 

ultra-low NOx burners available. The cost is in excess of the District’s BACT threshold, 

so the applicant is not required to purchase the 9 ppm boiler. The increment between 
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Appendix E – Attachment 1: ISR Spending Plan December 15, 2005

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the 15 ppm boiler and the 9 ppm boiler are therefore surplus reductions. The incentive 

amount would be set to cover the extra cost of installing the cleaner boiler. There are 

approximately 420 units between 5 to 20 MMBTU per hour that are subject to Rule 

4306. Complete new burner unit costs are in the range of $28,000 to $57,000 

depending on size, based on contact with venders. The differential cost between low 

emitting and high emitting burners ranges from $5,000 to $7,000

Another possible source of surplus reductions may occur from boilers rated from 2 to 5 

MMBTU per hour and subject to proposed Rule 4307, which has a NOx limit of 30 ppm. 

Some boilers that currently operate above 30 ppm may be exempt from rule retrofit 

requirements now under development, so the surplus reductions for those units may be 

calculated from the uncontrolled emissions of 55 ppm down to 9 ppm. The incentive 

would need to cover 100 percent of the cost of the installation. There are no increased 

operating costs expected with the 9 ppm burners. There could be more than 300 of 

these exempt units eligible for an incentive. Unit costs for 2.5 MMBtu/hr 9 ppm burners 

are about $41,000 based on contact with vendors.

Example: Electrification of stationary non-emergency IC engines.

Stationary engines are required to meet a NOx emission limit specified by Rule 4702. 

Installing an electric motor in place of the engine would result in a surplus reduction for 

the increment between the emission limit and the zero emission electric motor. 

Depending on the current electric rate and price of fuel, there may be a cost increase 

from changing to electric. The incentive would need to cover the cost of replacing the 

engine with an electric motor and increased operating costs. There are hundreds of 

units installed that could take advantage of this program with sufficient incentive 

amounts. Costs have not been researched.

Example: Install SCR at a flat glass melting furnace.

Glass melting furnaces are required to meet NOx emission limits specified in Rule 4354 

when the furnace is next rebuilt. These furnaces are rebuilt approximately every 7 

years. The rule requirements can be exceeded with installation of selected catalyst 

reduction. The surplus reductions can be achieved by using SCR instead of oxy fuel or 

in addition to oxy fuel in some cases. The cost of control may exceed $10 million per 

unit, but the large potential emission reductions result in relatively good costeffectiveness. SCR has high operating costs and would most likely require incentives to 

cover increased operating costs. There are two potential candidates for this project in 

the San Joaquin Valley.

Example: Install plenum chambers or additional cyclone separators in cotton 

gins.

Cotton gins are required to reduce PM10 emissions produced during the ginning 

process under Rule 4204. Additional controls may be possible for some gins if an 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E – Attachment 1: ISR Spending Plan December 15, 2005

Final Draft Staff Report for Proposed

 Rule 9510 and Rule 3180

E - 18

incentive were provided. Installing a plenum chamber before the required cyclone 

separators may provide reductions if there is room for the equipment in the building. 

After the cyclone separators there may be potential to add either cyclone separators in 

or a bag house in series. Feasibility will depend on the gin configuration. There are 

increased operating costs with adding cyclone separators and bag houses that may 

impact cost-effectiveness of these options.

PM10 Public Agency Road and Unpaved Surface Program

The District has identified several sources of fugitive PM10 from paved and unpaved 

roads that provide significant emission reduction potential for the ISR rule. The most 

promising projects are:

• Paving unpaved roads

• Paving unpaved road shoulders

• Long-term contracts for chemical suppressants on unpaved roads

• Long-term contracts for chemical dust suppressants on unpaved road shoulders

• Purchase of PM10 Efficient Street Sweepers

Program Concept

The District envisions this program as a coordinated effort between the District, Valley 

Transportation Planning Agencies, city and county road agencies, and public works 

departments. The funds collected for PM10 will be spent in the county of origin to the 

extent possible. 

The District will develop an application process and evaluation procedure for funding 

road projects. Some of the key features are outlined below:

General Program Features

1. Each county and the cities within each county will be competing for funds 

generated in the county

2. The Council of Governments/Transportation Planning Agencies may coordinate 

the process of identifying funding priorities among the local member jurisdictions.

3. The primary consideration in funding priorities is cost-effectiveness.

4. Projects must not supplant funding from any source.

5. A mix of projects with higher cost-effectiveness may be funded as long as the 

average cost-effectiveness for the year is consistent with the District’s annual 

target.

6. Once a list of eligible projects is created and ranked, funding would be allocated 

twice each year as fees are collected by the District. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E – Attachment 1: ISR Spending Plan December 15, 2005

Final Draft Staff Report for Proposed

 Rule 9510 and Rule 3180

E - 19

Unpaved Roads

1. Provide a list of unpaved road segments in descending average daily trip (ADT) 

sequence (same data used for compliance with Rule 8061).

2. Indicate road segments that will be paved or chemical treated in compliance with 

Rule 8061.

3. If economic hardship is claimed for Rule 8061, provide justification.

4. As a general rule, the highest ADT road segments should be paved or treated 

first.

5. Other factors to consider in scoring projects:

Roads with significant truck traffic should receive added points

Roads in or near to urban areas should receive added points

6. Payment will be made to the agency after the project is complete.

7. Suppressant projects would be paid annually under a continuing agreement.

8. A single project could be based on total miles of road segments from a 

jurisdiction so that different roads could be done under one contract.

Paved Road Shoulder Paving Projects

1. Provide a list of unpaved road shoulders in descending average daily trip (ADT) 

sequence (same list used for compliance with Rule 8061). 

2. Indicate road shoulder segments that will be paved or chemical treated in 

compliance with Rule 8061.

3. Other criteria should be same as unpaved road projects

PM10 Efficient Street Sweepers

1. Provide a description of the existing street sweeping program if any, including 

sweeping schedule and types of sweepers (PM Efficient or Standard)

2. Demonstrate compliance with Rule 8061 sweeper purchase requirements or 

provide economic hardship justification.

3. Provide an estimate of the curb miles that will be swept by the new sweeper(s).

4. Projects proposing natural gas vehicles may be eligible for additional funding 

based on NOx and PM10 exhaust emission reductions.

Agricultural Project Incentive Program

The District has identified several potential projects for agricultural equipment and 

emission sources not currently eligible for other funding sources. The projects must be 

surplus to agricultural regulations and be able to demonstrate quantifiable emission 

reductions.

Program Concept: Although many agricultural sources are now regulated, there are 

some opportunities for early implementation of controls that are scheduled far enough in 

the future to result in surplus reductions. In some cases, it is possible to go beyond 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E – Attachment 1: ISR Spending Plan December 15, 2005

Final Draft Staff Report for Proposed

 Rule 9510 and Rule 3180

E - 20

current regulations. For example, measures in addition to those required by the 

Agricultural Conservation Management Program rule. 

Agricultural Projects:

v Lower emitting almond harvester purchase

v Chippers and shredder purchases as alternative to burning

Project descriptions:

New almond harvesters that emit 35 to 70 percent less PM10 than older units are 

currently available. Field-testing results completed for the harvesters is currently under 

analysis by UC Davis. Early introduction of lower emitting almond harvesters will result 

in significant reductions. 

Chipping and shredding wood waste in the orchard instead of burning results in 

substantial reductions of PM10, NOx, and ROG. Although Rule 4103 phases out most 

burning by 2010, some will be exempt due to lack of an economic alternative to burning. 

The District would purchase chippers and shredders for growers that were unable to 

implement an alternative to burning and had not selected this as a practice for their 

CMP Plan.

IV. Potential Projects Lists for NOx and PM10

The following tables list potential projects along with estimates of the number of 

potential projects, costs, emission reductions and cost-effectiveness for each type of 

project. The purpose of the list is to show that sufficient projects are available at a costeffectiveness to achieve program goals. The list is not all inclusive. There are many 

Heavy-Duty Engine Incentive Program and REMOVE II eligible projects that could also 

be funded. New projects may also become available as retrofit devices are certified and 

new technologies are released to the market. The conclusion that can be drawn from 

this information is that projects well in excess of projected funding are available for the 

ISR program.

Tables are also provided for 2006, 2007, and 2008 containing a demonstration that the 

cost-effectiveness targets can be met with the types of projects that are available. This 

is not intended as a funding allocation system. Participation in grant programs is 

voluntary and on a first come, first served basis. The District may perform targeted 

outreach and may set up funding pots for the most cost-effective projects if necessary to 

achieve emission reduction commitments.
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E – Attachment 1: ISR Spending Plan December 15, 2005

Final Draft Staff Report for Proposed

 Rule 9510 and Rule 3180

E - 21

NOx Project Availability

Individual 

Project Cost

Annual 

Reduction 

(t/y)

Project 

Life

Lifetime 

Reductions

Project CE 

$/ton

Projects 

Available Total Cost Cumulative Cost

Category 

Reductions 

Life (tons)

Total 

Reductions 

t/d

Cumulative 

Reductions 

tons

Cumulative 

CE

Marine Vessels (Harbor Craft) 04 repower $197,850 7.6 16 121.6 1627.5 1 $197,850 $197,850 121.57 0.02 121.6 $1,627.46

Ag Irrigation Pump Electrification $21,558 3.0 10 29.9 720.8 142 $3,061,273 $3,259,124 4247.22 0.58 4368.8 $746.00

Marine Vessels (Harbor Craft) 03 repower $69,288 3.3 16 52.8 1313.3 1 $69,288 $3,328,412 52.8 0.01 4421.6 $752.77

Ag Irrigation Pumps Portable Diesel Repowers $27,144 2.3 7 15.9 1705.0 50 $1,357,198 $4,685,610 796.0 0.11 5217.6 $898.05

HDD Trucks Idle Reduction $9,883 0.6 5 3.0 3316.3 320 $3,162,411 $7,848,021 953.6 0.13 6171.2 $1,271.73

Open Burning Chippers Almond $227,182 5.7 10 57.2 3971.7 1 $227,182 $8,075,203 57.2 0.01 6228.4 $1,296.52

Off-Road Vehicles/Equipment large ag $48,382 1.7 7 11.8 4100.2 10 $483,820 $8,559,023 118.0 0.02 6346.4 $1,348.65

Auxiliary Power Units (Transportation 

Refridgeration Units) $12,518 0.4 5 1.8 6878.1 294 $3,680,348 $12,239,371 535.1 0.07 6881.4 $1,778.61

Ag non self-propelled ICE $9,200 0.1 7 1.0 8846.2 10 $92,000 $12,331,371 10.4 0.00 6891.8 $1,789.27

On-Road HD Vehicles - Fleet Modernization $88,756 1.0 10 10.2 8744.4 1000 $88,755,962 $101,087,334 10150.0 1.39 17041.8 $5,931.72

Glass Melting Furnaces - SCR $22,120,500 239.0 10 2390.0 9255.4 1 $22,120,500 $123,207,834 2390.0 0.33 19431.8 $6,340.52

Off-Road Vehicles/Equipment small ag repowers $12,677 0.2 7 1.3 9981.9 20 $253,540 $123,461,374 25.4 0.00 19457.2 $6,345.27

Ag non self-propelled ICE - repowers $15,500 0.2 7 1.5 10402.7 12 $186,000 $123,647,374 17.9 0.00 19475.1 $6,348.99

Small Boilers, Steam Generators, and Process 

Heaters - replacement $13,000 0.1 10 1.2 10743.8 1207 $15,691,000 $139,338,374 1460.5 0.20 20935.6 $6,655.58

School Bus Replacement $110,000 0.3 10 3.1 35483.9 1000 $110,000,000 $249,338,374 3100.0 0.42 24035.6 $10,373.72

Locomotives $1,414,286 6.0 18.6 111.7 12664.7 10 $14,142,857 $263,481,231 1116.7 0.15 25152.3 $10,475.44

Small Boilers, Steam Generators, and Process 

Heaters - replacement $6,000 0.0 10 0.3 18181.8 552 $3,312,000 $266,793,231 182.2 0.02 25334.5 $10,530.85

Forklifts (Electric, ICE, SI) $44,457 0.4 5 2.0 22798.7 50 $2,222,873 $269,016,104 97.5 0.01 25432.0 $10,577.88

Airport Ground Support Equipment - Electric 

replacements $27,889 0.2 5.0 1.1 24753.5 73 $2,035,889 $271,051,993 82.2 0.01 25514.2 $10,623.57

Open Burning Chippers Figs $185,212 0.6 10 5.7 32379.7 12 $2,222,544 $273,274,537 68.6 0.01 25582.8 $10,681.95

Gross Polluter - VAVR $3,000 0.1 1 0.08 37500.0 100 $300,000 $273,574,537 8.0 0.00 25590.8 $10,690.33

Old Vehicle - VAVR $3,000 0.02 3 0.06 50000.0 5000 $15,000,000 $288,574,537 300.0 0.04 25890.8 $11,145.82

25890.8 3.55
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E – Attachment 1: ISR Spending Plan December 15, 2005

Final Draft Staff Report for Proposed

 Rule 9510 and Rule 3180

E - 22

PM10 Project Availability

Individual 

Project 

Cost

Annual 

PM10 

Reduction 

(t/y)

Project 

Life

Lifetime 

Reductions

Project 

CE 

$/ton

Projects 

Available Total Cost

Cumulative 

Cost

Category 

Reductions 

Life (tons)

Total 

Reductions 

t/d

Cumulative 

Reductions 

tons

Cumulative 

CE

Unpaved Roads - City and County

Paving 75 ADT roads $290,000 27.1 20 542.0 535.1 10 $2,900,000 $2,900,000 5420 0.7 5420 $535.06

Paving 25 ADT roads $290,000 9.0 20 180.7 1605.2 90 $26,100,000 $29,000,000 16260 2.2 21680 $1,337.64

Paving 10 ADT roads $290,000 3.6 20 72.0 4027.8 100 $29,000,000 $58,000,000 7200 1.0 28880 $2,008.31

Suppressants 10 year contract $140,080 3.5 10 35.0 4002.3 100 $14,008,000 $72,008,000 3500 1.0 32380 $2,223.84

Paved Roads 32380

Paving Shoulders $100,000 0.2 20 3.8 26315.8 500 $50,000,000 $122,008,000 1900 0.5 34280 $3,559.16

Suppresants on Shoulder 10 yr $48,370 0.2 10 1.6 30231.3 500 $24,185,000 $146,193,000 800 0.2 35080 $4,167.42

PM Efficient Street Sweepers $152,000 0.9 8 7.3 20821.9 15 $2,280,000 $148,473,000 109.5 0.0 35189.5 $4,219.24

Stationary Source Projects

Cotton Gin - Install barrel cyclone 

before master trash 1D3D cyclone $7,500 1.6 10 16.3 460.1 12 $90,000 $148,563,000 195.6 0.0 35275.6 $4,211.49

Cotton Gin - Install barrel cyclone 

or 1D2D cyclone before mote 

system 1D3D cyclone $60,000 2.8 10 27.6 2173.9 12 $720,000 $149,283,000 331.2 0.0 35606.8 $4,192.54

Cotton Gin - Install plenum 

chamber before the unloading 

system and the drying/cleaning 

systems $70,000 2.8 10 27.6 2536.2 12 $840,000 $150,123,000 331.2 0.1 35938 $4,177.28

Charbroiler Replacement $6,600 0.2 10 2.4 2750.0 135.0 $891,000 $151,014,000 324 0.1 36262 $4,164.52

Other Ag Projects

Almond Harvester Purchase $145,000 3.6 10 35.7 4061.6 260 $37,700,000 $188,714,000 9282 2.5 45220 $4,173.24

8.5
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E – Attachment 1: ISR Spending Plan December 15, 2005

Final Draft Staff Report for Proposed

 Rule 9510 and Rule 3180

E - 23

NOx Cost-Effectiveness Demonstration

NOx Project Mix in 2006 to achieve an average cost effectiveness of $4650/ton with $6,006,379 available

Project 

Cost

Annual 

Reduction 

(t/y) Project Life

Life 

Reductions

Total No. 

Projects 

Available

Number of 

Projects 

in 2006 Total cost

Total 

tons

Project CE 

$/ton

Ag Projects

Ag Irrigation Pump 

Electrification $21,558 3.0 10 29.9 142 20 $431,165 598.2 721

Ag Irrigation Pumps 

Portable Diesel Repowers $27,144 2.3 7 15.9 50 10 $271,440 159.2 1,705

Off-Road 

Vehicles/Equipment large 

ag repowers $48,382 1.7 7 11.8 10 4 $193,528 47.2 4,100

Ag non self-propelled ICE 

repowers hay bayler $9,200 0.1 7 1.0 10 1 $9,200 1.0 8,846

Ag non self-propelled ICE 

repowers spray rig $15,500 0.2 7 1.5 12 2 $31,000 3.0 10,403

Off-Road 

Vehicles/Equipment small 

ag repowers $12,677 0.2 7 1.3 20 3 $38,031 3.8 9,982

Open Burning - Chipping 

Almonds $227,182 5.7 4 22.9 1 1 $227,182 22.9 9,921

Open Burning - Chipping 

Figs $185,212 0.6 4 2.28 12 1 $185,212 2.3 81,233

Marine Projects

Marine Vessels (Harbor 

Craft) 03 repower $69,288 3.3 16 52.8 1 1 $69,288 52.8 1,313

Marine Vessels (Harbor 

Craft) 04 repower $197,850 7.6 16 121.6 1 1 $197,850 121.6 1,627

HD Truck/Bus Projects

HDD Trucks Idle 

Reduction $9,883 0.6 5 3.0 320 0 $0 0.0 #DIV/0!
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E – Attachment 1: ISR Spending Plan December 15, 2005

Final Draft Staff Report for Proposed

 Rule 9510 and Rule 3180

E - 24

NOx Cost-Effectiveness Demonstration

NOx Project Mix in 2006 to achieve an average cost effectiveness of $4650/ton with $6,006,379 available

HD Truck/Bus Projects

Cont

Auxiliary Power Units 

(Transportation 

Refridgeration Units) 

repowers $12,518 0.4 5 1.8 294 20 $250,364 36.4 6,878

On-Road HD Vehicles 

Fleet Modernization $88,756 1.0 10 10.2 1000 10 $887,560 101.5 8,744

School Bus Replacement $110,000 0.3 10 3.1 1000 9 $990,000 27.9 35,484

Locomotives Tier 0 to Tier 

2 or hybrid $1,414,286 6.0 18.6 111.7 10 1 $1,414,286 111.7 12,665

Stationary Source Projects

Glass Melting Furnaces $22,120,500 239.0 10 2390.0 1 0 $0 0.0 #DIV/0!

Small Boilers, Steam 

Generators, and Process 

Heaters Replace Existing 

units with new $13,000 0.1 10 1.2 1207 1 $13,000 1.2 10,744

Small Boilers, Steam 

Generators, and Process 

Heaters Replace Existing 

units with new $6,000 0.0 10 0.33 552 12 $72,000 4.0 18,182

Off-Road Mobile

Forklifts (Electric, ICE, SI) $44,457 0.4 5 1.95 50 5 $222,287 9.8 22,799

Airport Ground Support 

Equipment - Electric $27,889 0.2 5 1.13 73 3 $83,667 3.4 24,753

Other Mobile

Gross Polluter - VAVR $3,000 0.1 1 0.08 100 0 $0 0.0 #DIV/0!

Old Vehicle - VAVR $3,000 0.02 3 0.06 5000 150 $450,000 9.0 50,000

Overall cost and average CE for 2006 $6,037,059 1316.7 4,585
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E – Attachment 1: ISR Spending Plan December 15, 2005

Final Draft Staff Report for Proposed

 Rule 9510 and Rule 3180

E - 25

NOx Project Mix in 2007 to achieve an average cost effectiveness of $7100/ton with $14,407,974 available

Project 

Cost

Annual 

Reduction 

(t/y) Project Life

Life 

Reductions

Total No. 

Projects 

Available

Number of 

Projects 

in 2007 Total cost

Total 

tons

Project CE 

$/ton

Ag Projects

Ag Irrigation Pump 

Electrification 21,558 3.0 10 29.9 122 20 $431,165 598.2 721

Ag Irrigation Pumps 

Portable Diesel Repowers 27,144 2.3 7 15.9 40 20 $542,879 318.4 1,705

Off-Road 

Vehicles/Equipment large 

ag repowers 48,382 1.7 7 11.8 6 4 $193,528 47.2 4,100

Ag non self-propelled ICE 

repowers hay bayler 9,200 0.1 7 1.0 9 4 $36,800 4.2 8,846

Ag non self-propelled ICE 

repowers spray rig 15,500 0.2 7 1.5 10 4 $62,000 6.0 10,403

Off-Road 

Vehicles/Equipment small 

ag repowers 12,677 0.2 7 1.3 17 4 $50,708 5.1 9,982

Open Burning - Chipping 

Almonds 227,182 5.7 3 17.2 0 0 $0 0.0 #DIV/0!

Open Burning - Chipping 

Figs 185,212 0.6 3 1.71 11 0 $0 0.0 #DIV/0!

Marine Projects

Marine Vessels (Harbor 

Craft) 03 repower 69,288 3.3 16 52.8 0 0 $0 0.0 #DIV/0!

Marine Vessels (Harbor 

Craft) 04 repower 197,850 7.6 16 121.6 0 0 $0 0.0 #DIV/0!

HD Truck/Bus Projects 0

HDD Trucks Idle 

Reduction 9,883 0.6 5 3.0 320 0 $0 0.0 #DIV/0!

Auxiliary Power Units 12,518 0.4 5 1.8 274 40 $500,728 72.8 6,878
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E – Attachment 1: ISR Spending Plan December 15, 2005

Final Draft Staff Report for Proposed

 Rule 9510 and Rule 3180

E - 26

NOx Project Mix in 2007 to achieve an average cost effectiveness of $7100/ton with $14,407,974 available

HD Truck/Bus Projects

Cont.

On-Road HD Vehicles -

Fleet Modernization 88,756 1.0 10 10.2 990 45 $3,994,018 456.8 8,744

School Bus Replacement 110,000 0.3 10 3.1 991 40 $4,400,000 124.0 35,484

Locomotives 1,414,286 6.0 18.6 111.7 9 2 $2,828,571 223.3 12,665

Stationary Source Projects 0

Glass Melting Furnaces 22,120,500 239.0 10 2390.0 1 0 $0 0.0 #DIV/0!

Small Boilers, Steam 

Generators, and Process 

Heaters Replace Existing 

units with new 13,000 0.1 10 1.2 1206 2 $26,000 2.4 10,744

Small Boilers, Steam 

Generators, and Process 

Heaters Replace Existing 

units with new 6,000 0.0 10 0.33 540 6 $36,000 2.0 18,182

Off-Road Mobile

Forklifts (Electric, ICE, SI) 44,457 0.4 5 1.95 45 3 $133,372 5.9 22,799

Airport Ground Support 

Equipment - Electric 27889 0.2 5.0 1.13 70 4 $111,556 4.5 24,753

Other Mobile

Gross Polluter - VAVR $3,000 0.1 1 0.08 100 5 $15,000 0.4 37,500

Old Vehicle - VAVR $3,000 0.02 3 0.06 4850 350 $1,050,000 21.0 50,000

Overall cost and average CE for 2007 $14,412,326 1892.0 7,617
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E – Attachment 1: ISR Spending Plan December 15, 2005

Final Draft Staff Report for Proposed

 Rule 9510 and Rule 3180

E - 27

NOx Project Mix in 2008 to achieve an average cost effectiveness of $9350/ton with $22,373,287 available

Project 

Cost

Annual 

Reduction 

(t/y)

Project 

Life

Life 

Reductions

Total No. 

Projects 

Available

Number of 

Projects 

in 2008 Total cost Total tons

Project CE 

$/ton Comments

Ag Projects

Ag Irrigation Pump 

Electrification 21,558 3.0 10 29.9 102 18 $388,049 538.4 721

Ag Irrigation Pumps Portable 

Diesel Repowers 27,144 2.3 7 15.9 20 10 $271,440 159.2 1,705

Off-Road Vehicles/Equipment 

large ag repowers 48,382 1.7 7 11.8 2 2 $96,764 23.6 4,100

Ag non self-propelled ICE 

repowers hay bayler 9,200 0.1 7 1.0 5 5 $46,000 5.2 8,846

Ag non self-propelled ICE 

repowers spray rig 15,500 0.2 7 1.5 6 6 $93,000 8.9 10,403

Off-Road Vehicles/Equipment 

small ag repowers 12,677 0.2 7 1.3 13 8 $101,416 10.2 9,982

Open Burning - Chipping 

Almonds 227,182 5.6 2 11.1 1 1 $227,182 11.1 20,467

Rule 4103 2010 

Implementation

Open Burning - Chipping Figs 185,212 0.6 2 1.14 11 0 $0 0.0 #DIV/0!

Rule 4103 2010 

Implementation

Marine Projects

Marine Vessels (Harbor Craft) 

03 repower 69,288 3.3 16 52.8 0 0 $0 0.0 #DIV/0!

Marine Vessels (Harbor Craft) 

04 repower 197,850 7.6 16 121.6 0 0 $0 0.0 #DIV/0!

HD Truck/Bus Projects 0

HDD Trucks Idle Reduction 9,883 0.6 5 3.0 320 50 $494,127 149.0 3,316

Idle Aire req. min 

order of 50 units
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E – Attachment 1: ISR Spending Plan December 15, 2005

Final Draft Staff Report for Proposed

 Rule 9510 and Rule 3180

E - 28

NOx Project Mix in 2008 to achieve an average cost effectiveness of $9350/ton with $22,373,287 available

HD Truck/Bus Projects

Cont.

Auxiliary Power Units -

Repower 12,518 0.4 5 1.8 234 40 $500,728 72.8 6,878

On-Road HD Vehicles - Fleet 

Modernization 88,756 1.0 10 10.2 945 66 $5,857,894 669.9 8,744

School Bus Replacement 110,000 0.3 10 3.1 951 50 $5,500,000 155.0 35,484

Locomotives 1,414,286 6.0 18.6 111.7 7 4 $5,657,143 446.7 12,665

Stationary Source Projects 0

Glass Melting Furnaces 22,120,500 239.0 10 2390.0 1 0 $0 0.0 #DIV/0!

Small Boilers, Steam 

Generators, and Process 

Heaters Replace Existing 

units with new 13,000 0.1 10 1.2 1204 60 $780,000 72.6 10,744

Small Boilers, Steam 

Generators, and Process 

Heaters Replace Existing 

units with new 6,000 0.0 10 0.33 534 60 $360,000 19.8 18,182

Off-Road Mobile 0

Forklifts (Electric, ICE, SI) 44,457 0.4 5 1.95 42 5 $222,287 9.8 22,799

Airport Ground Support 

Equipment - Electric 27889 0.2 5.0 1.13 10 5 $139,444 5.6 24,753

Other Mobile 0

Gross Polluter ID & Replace -

VAVR $3,000 0.1 1 0.08 95 50 $150,000 4.0 37,500

Old Vehicle - VAVR $3,000 0.02 3 0.06 4500 500 $1,500,000 30.0 50,000

Overall cost and average CE for 2008 $22,385,473 2391.7 9,359
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E – Attachment 1: ISR Spending Plan December 15, 2005

Final Draft Staff Report for Proposed

 Rule 9510 and Rule 3180

E - 29

NOx Cost Effectiveness Demonstration

Year

Nox

Projected Revenue NOx CE $/ton

2006 $6,006,379 4,650

2007 $14,407,974 7,100

2008 $22,373,287 9,350

Total $42,787,640
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E – Attachment 1: ISR Spending Plan December 15, 2005

Final Draft Staff Report for Proposed

 Rule 9510 and Rule 3180

E - 30

PM10 Cost-Effectiveness Demonstration

Project Mix in 2006 to achieve an average cost effectiveness of $2907/ton with $5,941,908 available

Project 

Cost

Annual 

Reduction 

(t/y) Project Life

Life 

Reductions

Total No. 

Projects 

Available

Number of 

Projects 

in 2006 Total cost

Total 

tons

Project CE 

$/ton

Unpaved Roads

 Paving 75 ADT roads $290,000 27.1 20 542 10 2 $580,000 1084.0 535

 Paving 25 ADT roads $290,000 9.0 20 180.7 90 2 $580,000 361.3 1,605

 Paving 10 ADT roads $290,000 3.6 20 72.0 100 4 $1,160,000 288.0 4,028

 Suppressants 10 year contract $140,080 3.5 10 35.0 100 6 $840,480 210.0 4,002

Paved Roads 

 Paving Shoulders $100,000 0.2 20 3.8 500 14 $1,400,000 53.2 26,316

 Suppresants on Shoulder 10 yr $48,370 0.2 10 1.6 500 16 $773,920 25.6 30,231

 PM Efficient Sweeper Purchase $152,000 0.9 8 7.3 25 2 $304,000 14.6 20,879

Cotton Gins

Install barrel cyclone before 

master trash 1D3D cyclone $7,500 1.6 10 16.3 12 2 $15,000 32.6 460

 Install barrel cyclone or 1D2D 

cyclone before mote system 

1D3D cyclone $60,000 2.8 10 27.6 12 2 $120,000 55.2 2,174

 Install plenum chamber before 

the unloading system and the 

drying/cleaning systems $70,000 2.8 10 27.6 12 2 $140,000 55.2 2,536

Other Ag Equipment

Almond Harvester Purchase $145,000 3.6 10 35.7 260 0 $0 0.0 #DIV/0!

Average CE in 2006

Overall cost and 

CE for 2006 $5,913,400 2179.7 2,713
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E – Attachment 1: ISR Spending Plan December 15, 2005

Final Draft Staff Report for Proposed

 Rule 9510 and Rule 3180

E - 31

Project Mix in 2007 to achieve an average cost effectiveness of $5594/ton with $20,861,575 available

Project 

Cost

Annual 

Reduction 

(t/y) Project Life

Life 

Reductions

Total No. 

Projects 

Available

Number of 

Projects 

in 2007 Total cost

Total 

tons

Project CE 

$/ton

Unpaved Roads

 Paving 75 ADT roads $290,000 27.1 20 542 8 0 $0 0.0 #DIV/0!

 Paving 25 ADT roads $290,000 9.0 20 180.7 88 5 $1,450,000 903.3 1,605

 Paving 10 ADT roads $290,000 3.6 20 72.0 96 22 $6,380,000 1584.0 4,028

 Suppressants 10 year contract $140,080 3.5 10 35.0 94 16 $2,241,280 560.0 4,002

Paved Roads 0

 Paving Shoulders $100,000 0.2 20 3.8 486 55 $5,500,000 209.0 26,316

 Suppresants on Shoulder 10 yr $48,370 0.2 10 1.6 484 50 $2,418,500 80.0 30,231

 PM Efficient Sweeper Purchase $152,000 0.9 8 7.3 23 12 $1,824,000 87.4 20,879

Cotton Gins

Install barrel cyclone before 

master trash 1D3D cyclone $7,500 1.6 10 16.3 10 2 $15,000 32.6 460

Install barrel cyclone or 1D2D 

cyclone before mote system 

1D3D cyclone $60,000 2.8 10 27.6 10 2 $120,000 55.2 2,174

Install plenum chamber before 

the unloading system and the 

drying/cleaning systems $70,000 2.8 10 27.6 10 2 $140,000 55.2 2,536

Other Ag Equipment

Almond Harvester Purchase $145,000 3.6 10 35.7 260 2 $290,000 71.4 4,062

Average CE in 2007

Overall cost and 

CE for 2007 $20,378,780 3638.1 5,602
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E – Attachment 1: ISR Spending Plan December 15, 2005

Final Draft Staff Report for Proposed

 Rule 9510 and Rule 3180

E - 32

Project Mix in 2008 to achieve an average cost effectiveness of $9011/ton with $33,883,309 available

Project 

Cost

Annual 

Reduction 

(t/y) Project Life

Life 

Reductions

Total No. 

Projects 

Available

Number of 

Projects 

in 2008 Total cost

Total 

tons

Project CE 

$/ton

Unpaved Roads

 Paving 75 ADT roads $290,000 27.1 20 542 8 1 $290,000 542.0 535

 Paving 25 ADT roads $290,000 9.0 20 180.7 83 5 $1,450,000 903.3 1,605

 Paving 10 ADT roads $290,000 3.6 20 72.0 74 10 $2,900,000 720.0 4,028

 Suppressants 10 year contract $140,080 3.5 10 35.0 78 5 $700,400 175.0 4,002

Paved Roads 0

 Paving Shoulders $100,000 0.2 20 3.8 431 175 $17,500,000 665.0 26,316

 Suppresants on Shoulder 10 yr $48,370 0.2 10 1.6 434 160 $7,739,200 256.0 30,231

 PM Efficient Sweeper Purchase $152,000 0.9 8 7.3 11 11 $1,672,000 80.1 20,879

Cotton Gins 0

 Install barrel cyclone before 

master trash 1D3D cyclone $7,500 1.6 10 16.3 8 2 $15,000 32.6 460

 Install barrel cyclone or 1D2D 

cyclone before mote system 

1D3D cyclone $60,000 2.8 10 27.6 8 2 $120,000 55.2 2,174

 Install plenum chamber before 

the unloading system and the 

drying/cleaning systems $70,000 2.8 10 27.6 8 2 $140,000 55.2 2,536

Other Ag Equipment

Almond Harvester Purchase $145,000 3.6 10 35.7 258 6 $870,000 214.2 4,062

Average CE in 2008

Overall cost and 

CE for 2008 $33,396,600 3698.6 9,029
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E – Attachment 1: ISR Spending Plan December 15, 2005

Final Draft Staff Report for Proposed

 Rule 9510 and Rule 3180

E - 33

PM10 Cost-Effectiveness Demonstration

Year

PM10 Projected 

Revenue PM10 CE $/ton

2006 $5,941,908 2,907

2007 $20,306,433 5,594

2008 $33,883,309 9,011

Total $60,131,650
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E – Attachment 1: ISR Spending Plan December 15, 2005

Final Draft Staff Report for Proposed

 Rule 9510 and Rule 3180

E - 34

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