November 6, 2007 

State of California 

AIR RESOURCES BOARD 

ARB Staff Report to the Air Resources Board: 

Accelerating 

San Joaquin Valley Air Quality Progress 

Date of Release: November 6, 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 

the mention of trade names or commercial products constitute endorsement of 

recommendation for use. 
November 6, 2007 

(This page intentionally blank.) 
November 6, 2007 i

TABLE OF CONTENTS 

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

 Conclusions and Recommendations 

 District Actions 

 Local Government Actions 

 Ongoing ARB Focus on the Valley 

INTRODUCTION ..................................................................................................1 

Background 

Public Process – Task Force and Community Meetings 

EMISSIONS INVENTORY DESCRIPTION AND REVIEW ...................................3 

Stationary Source Emissions 

Upcoming Inventory Improvements 

Stationary Sources 

Diesel Trucks and Mobile Agricultural Equipment 

REVIEW OF DISTRICT RULES AND MEASURES..............................................9 

State and Federal Technology Requirements for Stationary Sources 

Improving the Effectiveness of the District’s BACT Program 

Evaluation of San Joaquin Valley District Rule Stringency 

Gas and Liquid Fired Boilers, Process Heaters and 

Steam Generators 

Solid Fuel Fired Boilers, Process Heaters and Steam Generators 

Stationary Gas Turbines 

Stationary Internal Combustion Engines 

Glass Production Furnaces 

Dryers, Dehydrators, and Ovens 

Flares 

Other Opportunities 

Composting and Biosolids 

Dairies 

Burning 

POTENTIAL IMPACT ON PROGRESS TOWARD ATTAINMENT .....................23 

APPENDICES 

A. SUMMARY OF STRENGTHENED STATE IMPLEMENTATION PLAN 

 STRATEGY 

B. CALCULATION METHOD FOR AIR QUALITY PROGRESS METRIC 

C. TASK FORCE AND PUBLIC OUTREACH MATERIALS 

(Additional Resource Material available under separate cover on-line at: 

http:www.arb.ca.gov/planning/sip/sip.htm)
November 6, 2007 ii

(This page intentionally blank.)
November 6, 2007 iii

EXECUTIVE SUMMARY 

Attainment of the federal ozone standard in the San Joaquin Valley is a 

formidable public health challenge. In June 2007, the Air Resources Board (ARB 

or Board) approved the federally required San Joaquin Valley Ozone Attainment 

Plan (the “State Implementation Plan or SIP”). As part of the approval, two ARB 

Board members agreed to oversee a public process designed to pursue 

additional actions that would further accelerate clean air progress. This report 

provides ARB staff’s summary of what has been accomplished in that process 

and what it means in terms of the Valley’s ozone SIP. 

On September 27, 2007, ARB approved a strengthened State Strategy for the 

SIP that is expected to result in approximately a 90 percent improvement in air 

quality over the next ten years relative to compliance with the federal air quality 

standard. The strengthened SIP will substantially increase emission reductions 

of nitrogen oxides, the key ozone forming pollutant in the Valley. While the SIP 

includes a necessary legal attainment deadline of 2023, most of what needs to 

be done will be accomplished by 2017. 

Nonetheless, many Valley residents want assurance that air agencies are doing 

all they can to improve air quality as quickly as possible. Now that ARB’s portion 

of the SIP has been strengthened, ARB staff has focused on the San Joaquin 

Valley Air Pollution Control District’s (District) SIP element as part of our 

oversight role under State law. ARB staff has evaluated the District’s rules and 

SIP measures for industrial sources and found them to be as stringent as any in 

California. This assessment reflects recent actions by the District Board to 

implement previously approved SIPs, comply with the requirements of State law, 

and further tighten rules to achieve new reductions needed to meet the federal 

8-hour ozone standard. 

A snapshot of rule stringency taken ten year ago would have shown the South 

Coast District with the State’s most stringent rules, setting the benchmark for 

stationary source control. The picture today looks very different. Since early this 

decade, the Valley District has set aggressive rulemaking targets in its SIPs for 

ozone and particulate matter. As a result, its existing rules together with those 

under development now are on par with the South Coast’s. Information about 

the District’s and other Districts’ rules is included as an appendix to this report. 

The challenge that remains will require development and application of new 

technologies, increased efficiency across all sectors of the economy, land use 

and transportation policies that foster sustainable growth, and actions by Valley 

residents to reduce the air quality impacts of their daily activities. Incentive funds 

will help achieve early reductions as new regulatory requirements phase in. 

ARB staff has proposed several recommendations that would support such 

efforts. These recommendations are intended to supplement the approved SIP, 

and if successful, could later be quantified and credited towards attainment. 
November 6, 2007 iv

Conclusions and Recommendations 

The San Joaquin Valley‘s Air Pollution Control District (District), along with local 

cities, counties, and transportation agencies, all have important roles to play in 

reducing air pollution as the region continues to grow. The District’s rules 

currently meet State and federal SIP stringency requirements. However, as 

technology advances, additional cost-effective applications are expected. Air 

Resource Board (ARB or Board) staff recommends the following processes and 

ongoing assessments to ensure continued progress in reducing emissions in the 

region. 

District Actions 

Industrial and Commercial Facilities 

• The District should complete its effort to raise its cost-effectiveness thresholds 

for Best Available Control Technology (BACT) for new air pollution sources 

consistent with other air districts’ thresholds. This would expand the universe 

of potential control technologies the District considers in the permitting 

process. 

• The District should widen its search for cutting-edge technologies by looking 

beyond the Valley for new control techniques. This includes looking at other 

California air district control technology databases as well as looking 

elsewhere in the country and internationally. 

• In assessing the applicability of technologies, the District should consider the 

feasibility of technology transfers from one source type to another. 

• The District should continue to look for opportunities to expand the use of 

technologies identified in the International Sustainable Systems Research 

Center (ISSRC) draft August 2007 report. Continuing efforts to electrify 

agricultural pumps is an example. ARB staff supports a partnership with the 

District and agriculture industry to bring about the necessary action by the 

Public Utilities Commission. 

• The District Board should periodically review, in a public setting, the current 

state-of-technology and potential for future technology development. 

• The District should continue its local task force as a means to identify ways to 

speed progress and should expand its purview to include industrial sources 

as well as mobile sources. 

• Where appropriate the District should continue to address localized impacts 

of sources through the nuisance provisions of state law. 
November 6, 2007 v

• The District should participate in the State’s effort to design strategies to 

reduce greenhouse gas emissions from manure management and any other 

strategies that may have a co-benefit of reducing ozone forming pollutants. 

Clean Air Days

• The District should encourage actions by Valley residents and businesses to 

reduce emissions on days with high ozone levels. The District has begun to 

develop a Clean Air Day concept and should continue on that path. 

Local Government Actions 

Land Use and Transportation 

• The region should develop cohesive policies to support land use and 

transportation decisions that foster sustainable growth. The District should 

take a leadership role and engage with other local agencies to bring air 

quality concerns more broadly into regional decision making. The region’s 

nascent Blueprint can set the stage. 

Local Funding Decisions 

• The local governments receiving federal Congestion Mitigation and Air Quality 

(CMAQ) funds should give funding priority to projects that provide real, costeffective emissions reductions. 

• The District should continue to work with ARB to maximize the use of 

incentive funds to achieve early emission reductions in the Valley. The 

District is already very active in the public process for obtaining Proposition 

1B bond monies, and the California Partnership for the San Joaquin Valley 

has been an important voice in indentifying the need for additional funding. 

Ongoing ARB Focus on the Valley 

In September, to accelerate air quality progress in the San Joaquin Valley, ARB 

strengthened the State Strategy for car, trucks, and construction and agricultural 

equipment. To follow up in September’s actions, ARB will bolster its efforts in the 

Valley on public education, outreach, and advanced technology development. 

ARB Rulemaking 

• The air quality status of the San Joaquin Valley will be explicitly considered as 

ARB staff develops major new regulations. Over the next year the key focus 

is the fleet rule for heavy diesel trucks. At the September Board meeting, 

ARB strengthened its measure for agricultural equipment cleanup. This 

measure will be a high priority for the Board. 
November 6, 2007 vi

ARB Community Outreach

• ARB Staff will continue its community-oriented public workshops throughout 

the Valley on rulemaking, bond funding, climate change, and other issues as 

they come forward. 

Technology Advancement

• ARB staff is working with US EPA on a New Technology Forum to be held in 

the San Joaquin Valley in 2008. The goal is to showcase new technologies 

that will provide many of the new near-term emission reductions in the 

Valley’s ozone SIP, as well as potential longer-term technology 

advancements. 

Public Education 

• ARB staff will hold a public education forum in the Valley in 2008 focused on 

the science of air pollution in the Valley. ARB staff will develop community 

oriented presentations on the science underlying California’s effort to improve 

air quality in the San Joaquin Valley. The forum is planned for UC Merced to 

facilitate academic participation. 

ARB SIP Progress Reports

• ARB staff will report annually to the Air Resources Board on the progress in 

implementing San Joaquin Valley SIPs for both ozone and particulate matter, 

the rate of emission reductions, and the status of air quality. 

Reports to the San Joaquin Valley District Board 

• ARB staff will continue to provide a monthly update at District Board meetings 

on topics of interest to the Board. 
November 6, 2007 1

INTRODUCTION 

Background 

The federally required 2007 Ozone Attainment Plan for the San Joaquin Valley 

was adopted by the District in May 2007. This SIP was developed in a public 

process that began in early 2006. Regulation of stationary sources (e.g., 

industrial and commercial facilities) is the responsibility of the District. The 

mobile source element of the plan is the responsibility of the ARB. These two 

components, combined with transportation strategies and required technical 

elements, comprise the SIP for a region. In June 2007 the ARB approved the 

District’s portion of the plan. In September 2007 ARB approved a new statewide 

mobile source strategy focused on the SIP needs of the San Joaquin Valley and 

South Coast Air Basin. 

Prior to adoption by the Board in September 2007, the ARB plan was 

strengthened considerably to speed progress toward the ozone standard in the 

Valley and to support fine particulate matter (PM2.5) attainment in the South 

Coast. The emission reductions for the Valley by 2017 from new ARB measures 

were increased by 50 percent compared to the original draft. ARB staff 

estimates that, when combined with reductions from local district actions, the 

strengthened State Strategy as adopted will improve Valley air quality by close to 

90 percent by 2018 when measured as progress toward the federal ozone 

standard. A summary of the strengthened State Strategy is included as an 

appendix to this report. 

With ARB’s portion of the SIP strengthened, ARB staff has focused on the 

District’s SIP element to answer the basic questions: do the District’s rules and 

SIP measures meet State and federal legal requirements for rule stringency and 

what actions should the District take to speed air quality progress? 

Staff’s review focused primarily on the District rules and measures for controlling 

oxides of nitrogen (NOx). Air quality science indicates that NOx reductions are 

relatively more beneficial for reducing ozone than are reductions of reactive 

organic gases, or ROG, and the Valley’s NOx reduction needs are large. Staff 

looked at the District’s adopted rules and SIP measures for limiting emissions 

from already existing sources and at the District’s New Source Review program 

that looks at emissions from new sources. Staff also examined the SIP inventory 

to assess the impact of recent inventory improvement work on progress toward 

attainment. 

Public Process – Task Force and Community Meetings 

In June 2007, at the ARB meeting to consider the District’s element of the SIP, 

the Board directed staff to conduct a public process to pursue additional actions 

that would further accelerate clean air progress. Two ARB Board members 

agreed to oversee the process. As part of the process, the Board directed staff 
November 6, 2007 2

to establish a task force to engage Valley environmental, business, and 

government leaders in the process and to hold community meetings to reach out 

directly to Valley citizens. 

As part of the public process directed by the Board, in August 2007, ARB staff 

convened a task force of business and industry advocates, air quality and public 

health advocates, and governmental leaders. A list of task force members is 

included in Appendix D. The task force has met four times to date, with a fifth 

meeting scheduled for November 7, 2007. The task force meetings all provide 

opportunity for public comment. The meetings agendas are included in 

Appendix D. 

In addition, community meetings were convened in each of the three Valley 

subregions – south, central and north. In August 2007, ARB staff held 

community meetings in Parlier and Arvin. On November 7, 2007, ARB staff will 

host a community meeting in Merced. These meetings provide the public with an 

opportunity to ask questions, share thoughts, and provide feedback to ARB staff 

and the Board. Spanish translation services are provided. 

The first three task force meetings, leading up to the September 27, 2007 ARB 

Board hearing on the State SIP Strategy for mobile sources, focused primarily on 

actions and efforts which could reduce mobile source emissions. In addition, 

authors of the ISSRC report staff briefed the task force and ARB staff on 

technologies identified in their report: “Clearing the Air: A Path to Clean Air by 

2017.” The ISSRC report took a broad-brush view of control technologies that 

they expected would be available in the near future and made across-the-board 

estimates of possible reductions if large-scale conversion to the ISSRC identified 

technologies were feasible. ARB staff briefed the task force on staff’s proposed 

strengthening of the mobile source strategy at the task force meeting on 

September 24, 2007. 

At its October 29, 2007 meeting, ARB staff briefed the task force on staff’s review 

of the SIP emissions inventory for stationary sources and District rules and SIP 

measures. At that meeting, the task force members requested that ARB staff 

broaden its review to include additional District rules. This report includes a 

review of those additional rules. ARB staff will present a summary of this report 

at the fifth task force meeting, scheduled for November 7, 2007. 
November 6, 2007 3

EMISSIONS INVENTORY DESCRIPTION AND REVIEW 

An estimate of the emissions in a region is the foundation of a SIP. Emission 

inventories undergo constant improvement as new information is gathered about 

sources and emission rates. However, to support SIP development, District and 

ARB staff must take a snapshot of the inventory as it exists at a given time and 

use that snapshot for SIP modeling and analysis. This inventory snapshot is 

used in the photochemical modeling to set overall emission reduction targets and 

to estimate the emission reductions from control measures. As SIPs are 

implemented and updated, new inventory information is taken into account. 

Since the SIP inventory was finalized in November 2006, District and ARB staffs 

have continued to work on inventory improvements. Even though the SIP 

inventory is set, understanding the potential impact of those improvements on 

emission reduction estimates and overall progress toward attainment is critical to 

assessing the question of accelerating progress. There are four important 

upcoming inventory changes: 

1. A pending District emissions update for devices that burn natural gas 

where the individual devices are not required to be permitted, due to their 

small size. Instead, the emissions are inferred from data other than from 

permits, i.e., total natural gas consumption in the Valley. 

2. A future District update of what emission sources are covered by certain 

District rules. 

3. A future ARB update of emissions from diesel trucks. 

4. A future ARB update of emissions from agricultural equipment (mostly 

tractors). 

Stationary Source Emissions 

ARB staff reviewed the emissions inventory for sources under District authority, 

in order to verify that the District has current emission control rules. The table 

below identifies the NOx emission sources in the Valley and the applicable 

emission control regulation. In a few instances, such as chemical and plastic 

manufacturing or metal plating and coating operations, the District controls 

emissions primarily for ROG or particulate matter (PM) benefits, but there may be 

small NOx emissions reported. These are so noted below. 
November 6, 2007 4

NOx Emission Sources and Applicable Emission Control Rules 

In the San Joaquin Valley 

(Summer Planning tons per day) 

Industrial Sector Equipment Type 

2006 

NOx 

Emissions 

Applicable 

District 

NOx 

Control 

Rules 

Boilers, Process Heaters, and Steam 

Generators 0.1 4306-4308 

Chemical Manufacturing 0.2 ROG/PM 

rules Chemical Plants 

Plastics And Plastic Products 

Manufacturing 0.1 ROG/PM rules 

Subtotal* 0.4 

Boilers, Process Heaters, and Steam 

Generators 2.7 4306-4308, 4352 

Internal Combustion Engines 0.2 4702 

Turbine Engines 6.0 4703 

Cogeneration 

Other 0.1 

Subtotal* 9.0 

Boilers, Process Heaters, and Steam 

Generators 2.6 4306-4308, 4352 

Internal Combustion Engines < 0.1 4702 Electric Utilities 

Turbine Engines 0.7 4703 

Subtotal* 3.3 

Boilers, Process Heaters, and 

Steam Generators 1.2 4306-4308 

Internal Combustion Engines < 0.05 4702 

Agricultural Irrigation I.C. Engines 27.2 4702 

Processing Losses 9.1 4306-4308, 

4309, 4352 

Agricultural Burning 5.1 4103 

Food And Agriculture 

Production And Processing 

Other 0.1 

Subtotal* 42.7 

Boilers, Process Heaters, and 

Steam Generators 1.2 4306-4308 

Oven, Dehydrators, and Dryers < 0.05 4309 

Internal Combustion Engines 1.6 4702 

Small Natural Gas Boilers** 32.5* 4307-4308 

Glass Manufacturing 7.6 4354 

Metal Plating And Coating 

Operations 0.1 ROG/PM rules 

Asphaltic Concrete Production 0.3 ROG/PM 

rules 

Manufacturing And Industrial 

Other 2.2 

Subtotal* 45.5 

(Continued next page)
November 6, 2007 5

(continued) 

Industrial Sector Equipment Type 

2006 

NOx 

Emissions 

Applicable 

District 

NOx 

Control 

Rules 

Boilers, Process Heaters, and 

Steam Generators 3.0 4306-4308, 4352 

Internal Combustion Engines 7.8 4702 

Turbine Engines 0.3 4703 

Oil And Gas Production 

Flares 0.1 4311 

Subtotal* 11.2 

Boilers, Process Heaters, and 

Steam Generators Petroleum Refining And 0.1 4306-4308 

Marketing Flares 0.2 4311 

Subtotal* 0.4 

Boilers, Process Heaters, and 

Steam Generators 2.4 4306-4308 

Internal Combustion Engines 0.7 4702 

Turbine Engines 0.5 4703 

Service And Commercial 

Oven, Dehydrators, and Dryers < 0.05 4309 

Subtotal* 3.6 

Incineration < 0.05 4302 Waste Disposal 

Flares < 0.05 4311 

Subtotal* < 0.05

Forest Management Forest Management 3.1 4103 

Subtotal* 3.1 

Wood Combustion - Wood Stoves 0.1 4901 Residential Fuel Combustion 2.7 4902, 4905 

Subtotal* 2.8 

Internal Combustion Engines not 

associated with a category above 1.4 4702 

Other 0.7 Other 

Fires – Structural and Automobile 0.3 

Subtotal* 2.4 

Total* 124.4 

* Numbers may not add up due to rounding conventions. 

** A discussion of the improvements to the methodology used to estimate emissions from 

unspecified natural gas combustion at manufacturing and Industrial sources follows. 

Upcoming Inventory Improvements 

Stationary Sources

The first of the two District inventory updates was submitted in November 2006. 

It is based on a new methodology for estimating emissions from NOx emissions 

from industrial equipment for which natural gas consumption or emissions are not 

reported for individual sources. In short, these are sources too small to fall into 
November 6, 2007 6

the district permitting program. Without permit data, emissions from these 

sources must be estimated from other information. 

The emissions for these so called “unspecified” manufacturing and industrial 

natural gas consumption sources in the 2007 Ozone Plan come from an estimate 

developed in the early 1990s. This estimate was carried forward into the current 

inventory. District staff recently reviewed this category and could find no 

documentation substantiating the existing estimate. Therefore, District staff 

developed a new methodology for estimating emissions and has submitted it to 

ARB for review and inclusion in future inventories. 

The table below shows the changes to the emissions inventory based on this 

improvement. As can be seen, the change is large. ARB staff has compared the 

new estimate with estimates from similar sources in other air districts. The new 

estimate compares well with other district data. ARB staff believes the 

methodology is a technically sound approach for estimating NOx emissions from 

these types of sources. 

Emissions Inventory Revisions for 

Unspecified Manufacturing and Industrial Natural Gas Combustion 

(Summer Planning tons per day) 

2006 2012 2017 2020 2023 

Emissions Estimate in 2007 Ozone Plan 32.5 35.5 38.4 39.8 40.3 

Revised Estimate 1.2 1.3 1.4 1.4 1.4 

Net Difference* 31.3 34.3 37.0 38.4 38.8 

* Numbers may not add up due to rounding conventions. 

The revised emission estimation methodologies use 2005 natural gas deliveries 

reported to the California Energy Commission (CEC), beyond that used by 

permitted stationary sources in the Valley, to estimate the NOx emissions from 

combustion of that natural gas. For emission estimation purposes, this natural 

gas is assumed to be combusted in a small uncontrolled industrial boiler, and 

uses U.S. EPA’s AP-42 emission factors. 

 

The second District inventory update relates to how the effectiveness of adopted 

District rules are reflected in the inventory, specifically rules 4307 and 4308 that 

govern emissions from boilers, steam generators, and process heaters. These 

types of devices are used in many industries as evidenced by the earlier table 

showing the Valley’s stationary source inventory. 

Emission reductions from rules are reflected in the inventory through control 

factors. The control factors themselves are a function of the existing level of 

control at affected sources and the emission reductions associated with the 

technologies underlying the rule. 
November 6, 2007 7

District staff believes that their current inventory methodology does not correctly 

apply control factors to many of the equipment units that are covered by District 

rules 4307 and 4308. Consequently, based on preliminary draft estimates1

, 

District staff believes that future emissions from these sources are 

overestimated. The table below shows the draft revised estimate for the benefits 

of these rules compared to the estimate the District provided for the 2007 Ozone 

Plan emissions inventory. 

ARB staff is in the process of reviewing these new emission control estimates. 

We expect to complete this work in early 2008 in time to include the final data in 

future SIP emission inventories. Like ARB’s potential mobile source inventory 

improvements, these anticipated changes will not impact the need to reclassify 

the region to extreme for ozone. 

Preliminary Revised Estimated NOx Reductions 

From Small and Medium-sized Boilers, 

Process Heaters and Steam Generators 

(SJV, Summer Planning tons per day) 

 2017 2020 2023 

2007 Ozone Plan Estimated Reductions 1.2 1.5 1.5 

Revised Estimated Reductions 5.2 6.0 6.6 

Net Difference 4.1 4.4 5.1 

Diesel Trucks and Mobile Agricultural Equipment

ARB staff is continually refining its understanding of emissions from cars, trucks 

and mobile equipment. This inventory improvement process is typically part of 

regulatory development. Inventories are refined as control strategies are more 

fully developed. An inventory improvement process is underway now in support 

of the rule that ARB staff is currently developing to clean up private diesel truck 

fleets. 

Preliminary review of data collected over the previous year indicates that the 

average age of trucks operating in the Valley may be younger than ARB staff has 

previously estimated. To the extent that trucks operating in the Valley are newer 

than previously thought, a revised diesel truck inventory will be smaller. Further, 

the corresponding reduction from the private truck fleet rule would be smaller as 

well. The potential impact of the possible truck emission inventory update and 

what it may mean to the fleet rule are included in the two tables below. 

This data is very preliminary. Data collection is still ongoing to complete and 

validate the emerging picture of the State’s diesel truck fleets. This effort is not 

 

1

 On October 25, 2007, District staff provided a revised draft assessment of the emissions 

benefits of rules 4307 and 4308 – regulating emissions from boilers, process heaters and steam 

generators rated between 75,000 British thermal units (btu) per hour and 5 million btu per hour. 
November 6, 2007 8

expected to be complete until some time next year. Until that work is complete, 

ARB staff is not able to estimate with certainty the impacts of any diesel truck 

inventory changes. ARB staff has presented this information here to help provide 

a general understanding of how future inventory changes may impact progress 

toward attainment of the ozone standard in the Valley. 

Potential Changes to On-road Heavy Duty Truck Emission Estimates 

in the San Joaquin Valley 

(Summer Planning tons per day) 

2017 2020 2023 

EMFAC2007 Emissions Estimate 113 87 72 

Possible Heavy-duty Truck Inventory Estimate Update 69 59 55 

Net Difference 44 28 17 

Potential Impact of Possible Changes to On-road Heavy Duty Truck 

Emission Estimates in the San Joaquin Valley on ARB’s 2007 State 

Strategy Commitment for Cleaner In-Use Heavy-duty Trucks 

(SJV, Summer Planning tons per day) 

2017 2020 2023 

SIP Measure 62 30 21 

Potential Emission Reduction Estimate Based 

Possible Inventory Changes 30 24 20 

Net Difference 32 7 1 

A similar inventory improvement effort is underway for emissions from 

agricultural equipment, especially tractors, in support of upcoming rule 

development for the cleanup of in-use agricultural equipment. The Board 

committed to develop a measure to clean up agricultural equipment as part of the 

State Strategy adopted in September 2007. 

That effort is in its very first stages, and ARB staff does not yet have enough 

information to provide a preliminary estimate of the potential changes to the 

inventory that may result. Depending on the relationships that are identified 

between such factors as useful life, activity by age and horsepower, and age 

distribution, future estimates could be either larger or smaller than the current 

estimate. 
November 6, 2007 9

REVIEW OF DISTRICT RULES AND MEASURES 

State and Federal Technology Requirements for Stationary Sources 

In California, each of the local air districts has rules governing existing stationary 

sources. These rules are known as prohibitory rules. They include requirements 

for emission limits, testing, recordkeeping, and reporting. Prohibitory rules may 

be generic, such as limiting the maximum level of a particular pollutant (such as 

oxides of nitrogen) at any facility, or they may address specific equipment, such 

as a turbine, a boiler, or an internal combustion engine. 

Prohibitory rule emission limitations reflect established emission control 

technologies that can be feasibly added to existing sources. The most stringent 

of these technologies are referred to as Best Available Retrofit Control 

Technology (BARCT). In addition to BARCT, federal law requires nonattainment 

areas to implement Reasonably Available Control Technology (RACT) at large 

stationary sources. 

In addition to district prohibitory rules that apply to existing sources, there are 

rules that apply to new or modified stationary sources. These are referred to as 

the New Source Review (NSR) program. The NSR program requires that large 

new sources, as well as existing sources undergoing large modifications, install 

the Best Available Control Technologies (BACT) as a part of the initial design of 

the source. 

When BACT is required, owners of sources must ensure that the equipment they 

are installing will not emit air pollutants at levels greater than those of similar new 

facilities. These limits are at least as stringent as the air district’s prohibitory 

rules. To identify BACT for a specific stationary source, air district staff needs to 

conduct a comprehensive evaluation of the cost and effectiveness of equipment, 

including obtaining testing results or similar proof that the emission levels have 

been achieved in practice. District staff is also expected to conduct a broad 

search (even internationally, at times) for technologies that have been 

demonstrated through testing on similar types of stationary sources to reduce 

emissions to the lowest levels. 

Once identified, the cost of the identified technology is compared to the air 

district’s BACT cost-effectiveness threshold. If the cost is lower than the 

threshold, then the technology can be designated as BACT in that district for that 

type of stationary source. 

The diagram below compares the general level of control compared to the 

relative cost of the control equipment for each of these levels of control. 
November 6, 2007 10

Relative Stringency and Costs of 

Emission Control Levels 

The best time to introduce new cutting-edge technologies is in the design phase 

of a new or modified stationary source. As engineers are designing the 

equipment and processes, they have the most flexibility to integrate the 

technology into the system to ensure the emission technology can achieve its 

maximum control efficiency. Integration costs are typically less as well. 

As technologies advance, BACT emission levels are subject to continuous 

improvement. Further, this improvement ultimately manifests in more stringent 

prohibitory rule levels and lower BARCT emission levels. As BACT technologies 

become more widely used for new stationary sources, engineering problems and 

limitation are solved and cost can come down. Air districts can then update their 

prohibitory rules to reflect these newer technology levels that are being achieved 

in practice. 

For example, low-NOx burners used in natural gas-fueled boilers that emitted 

NOx at 30 parts per million levels were previously considered BACT, and later 

were considered BARCT. Since then, BACT has advanced significantly, and 

BARCT in the Valley has dropped to levels as low as 5 ppm for some boiler 

sizes. 

Before a district can take the step of mandating the retrofit of existing equipment 

with more stringent technology, the technology must first be shown to be 

effective in a wide array of uses and operating conditions. BACT serves as the 

proving ground for air districts to evaluate the merits and applicability of new 

technologies to a range of sources. 

The ISSRC report recommends, for a number of different types of stationary 

equipment and facilities, modifying prohibitory rules to require technologies that 

have seen limited (if any) use in those settings. For example, the ISSRC report 

 -- Stringency ++ 

BARCT/

RACT 

BACT 

$$$

Cost 

$ 
November 6, 2007 11

recommends the District modify its prohibitory rule to require some solid fuel 

boilers to emit NOx at levels no higher than 40 ppm. ARB staff has not been 

able to identify a source that has achieved these levels in practice, and 

recommends a more exhaustive search of examples achieved in practice. If a 

technology that reduces levels of NOx from solid fuel boilers to 40 ppm is found, 

it would be most appropriately applied in the Valley as BACT, before migrating 

into a prohibitory rule. 

Improving the Effectiveness of the District’s BACT Program 

Because the BACT program plays such a key role in driving technology and the 

stringency of prohibitory rules, ARB reviewed the District’s process for identifying 

BACT to see if improvements would help to move the Valley’s technology 

benchmarks forward more rapidly. 

ARB staff has identified the following areas in which the Valley District could 

strengthen its BACT program. 

• The District should complete its effort to raise its cost-effectiveness thresholds 

for BACT. The District has not raised its BACT cost-effectiveness thresholds 

for ozone precursors since 1989, and they are substantially below those of 

other districts of similar or better air quality status. The District is currently 

proposing to modify its NOx cost-effectiveness thresholds so that they exceed 

those of SCAQMD, Bay Area Air Quality Management District (BAAQMD), 

Ventura Air Pollution Control District (VCAPCD), and San Diego Air Pollution 

Control District (SDAPCD). The table below compares BACT costeffectiveness thresholds used by various districts. 

California Air District BACT Cost-Effectiveness Thresholds 

District NOx 

[per ton] 

CO 

[per ton] 

VOC 

[per ton] 

PM10 

[per ton] 

SOx 

[per ton] 

SJVUAPCD (current) $9,700 $300 $5,000 $5,700 $3,900

SJVUAPCDa

(proposed update) $24,500 same $17,500 $11,400 $18,300 

BAAQMD $17,500 n/d $17,500 $5,300 $18,300 

SCAQMDb $19,100 $400 $20,200 $4,500 $10,100 

VCAPCD $18,000 $1,000 $18,000 $10,000 $10,000 

small 

source 

(<15 tpy) 

$13,200 n/d $7,480 n/d n/d 

SDAPCD large 

source 

(>15 tpy) 

$18,000 n/d $10,200 n/d n/d 

a

 Revisions are expected to be complete by early 2008. 

b

 Thresholds represent 2003 values. SCAQMD’s policy states that this figure should be adjusted 

to the latest Marshall and Swift Equipment Cost Index published monthly in Chemical 

Engineering. 
November 6, 2007 12

• The Valley District uses only its own BACT Clearinghouse to make BACT 

determinations, unless there are classes and categories of equipment not 

contained in the Clearinghouse. Conducting a broader technology search 

would help District staff become more aware of technology advancements in 

other jurisdictions, encourage the advancement of emission controls, and 

promote consistency statewide. 

• When determining whether a BACT control technology is achieved in practice 

for a given class or category of source, the District currently requires that the 

“type of business where the emission units are utilized must be the same.” 2

CAPCOA/ARB Guidance on Achieved in Practice BACT Determinations does 

not include business type as part of the criteria for achieved-in-practice BACT 

determinations. ARB staff believes that business type, in itself, does not 

warrant establishment of a different class or category of source unless unique 

operational or technical issues justify alternative emission levels. 

• The District should continue to look for opportunities to expand the use of the 

technologies identified in the ISSRC report, including electrification and SCR 

when making BACT determinations. 

Evaluation of San Joaquin Valley District Rule Stringency 

A snapshot of rule stringency taken ten years ago would have shown the South 

Coast District with the State’s most stringent rules, setting the benchmark for 

stationary source control. San Joaquin Valley District would have been seen 

lagging behind. The picture today looks very different. While the South Coast is 

still pushing the limits of stringency, the San Joaquin Valley District has caught 

up. Since early this decade, the District has set aggressive rulemaking targets in 

its SIPs for ozone and particulate matter. The tables below identify recent rules 

the District has adopted that limit ozone precursor emissions. As a result, its 

existing rules, together with those under development now, are on par with those 

in the South Coast. 

 

2

 Best Available Control Technology (BACT) Policy, San Joaquin Valley Unified Air Pollution 

Control District. November 9, 1999. Available on-line at: 

http://www.valleyair.org/policies_per/Policies/APR%201305.pdf 
November 6, 2007 13

Recent District NOx Rule Actions 

Rule Title Date 

6/21/2001 

9/16/2004 

5/19/2005 

4103 Open Burning 

5/17/2007 

4106 Prescribed Burning and Hazard Reduction Burning 6/21/2001 

9/18/2003 4306 Boilers, Steam Generators, and Process HeatersPhase 3 3/17/2005 

12/15/2005 4307 Boilers, Steam Generators, and Process Heaters - 

(2.0 MMBtu/hr to 5.0 MMBtu/hr) 4/20/2006 

4308 Boilers, Steam Generators, and Process Heaters - 

(0.075 MMBtu/hr to 2.0 MMBtu/hr) 10/20/2005 

4309 Dryers, Dehydrators, and Ovens 12/15/2005 

6/20/2002 4311 Flares 6/15/2006 

4352 Solid Fuel Fired Boilers, Steam Generators, and 

Process Heaters 5/18/2006 

2/21/2002 4354 Glass Melting Furnaces 8/17/2006 

4401 Steam Enhanced Crude Oil Production Wells 12/14/2006 

4408 Glycol Dehydration Systems 12/19/2002 

4693 Bakery Ovens 5/16/2002 

8/21/2003 

6/16/2005 

4/20/2006 4702 Internal Combustion Engines - Phase 2 

1/18/2007 

4/25/2002 

4703 Stationary Gas Turbines 8/17/2006 

9/20/2007 

4901 Wood Burning Fireplaces and Wood Burning Heaters 7/17/2003 

4905 Natural Gas Fired, Fan-type, Residential Central 

Furnaces 10/20/2005 
November 6, 2007 14

Recent District ROG Control Actions 

Rule Description Amendment 

Dates 

4403 

4409 

4451 

4452 

4455 

Components at Natural Gas Production Facilities, Chemical 

Plants, and Petroleum Refineries 4/20/2005 

4565 Biosolid, Animal Manure and Poultry Litter Operations 3/15/2007 

4570 Confined Animal Facilities 6/15/2006 

4601 Architectural Coatings 10/31/2001 

4602 

4603 12/20/2001 

4604 5/16/2002 

4605 4/17/2003 

4606 1/15/2004 

4607 5/18/2006 

4610 9/21/2006 

4612 

Various Coating Operations 

9/20/2007 

4622 Gasoline Transfer into Motor Vehicle Fuel Tanks 9/19/2002 

12/20/2001 4623 Storage of Organic Liquids 5/19/2005 

4651 Soil Decontamination Operations 9/20/2007 

12/20/2001 4653 Adhesives 9/20/2007 

12/20/2001 

4661 Organic Solvents 5/16/2002 

9/20/2007 

4/19/2001 

4662 Organic Solvent Degreasing Operations 12/20/2001 

9/20/2007 

12/20/2001 4663 Organic Solvent Cleaning, Storage and Disposal 9/20/2007 

4682 Polystyrene Foam Manufacturing 9/20/2007 

12/20/2001 4684 Polyester Resin Operations 9/20/2007 

4694 Wine Fermentation and Storage Tanks 12/15/2005

The following summarizes ARB staff’s review of the District’s nine most 

significant NOx control rules. Taken together, the nine rules plus the District’s 

open burning rule apply to nearly 95 percent of the stationary source NOx 

inventory. Staff’s overall conclusion is that the District’s rules are as stringent as 

any in the State. For completeness, staff has identified where the San Joaquin 

Valley’s District rules differ from those for similar sources in other air districts. 

These types of differences are typical. It might be possible to squeeze additional 

reductions from some sources through small incremental changes to emission 

limits, exemption levels, etc. The feasibility of these types of changes usually 

boils down to cost on an individual source basis, since the additional reductions 
November 6, 2007 15

are small compared to already stringent control levels. In terms of quantifiable 

new SIP reductions the additional increment of control would not likely be 

significant. 

Gas and Liquid Fuel Fired Boilers,

Process Heaters and Steam Generators

Existing San Joaquin Valley District Control Rule(s) 

Rule: 4306 – Boilers, Steam Generators, and Process Heaters – 

Phase 3 

Last Revised: March 17, 2005 

Applicability: This rule applies to any gaseous fuel or liquid fuel fired 

boiler, steam generator, or process heater with a total rated 

heat input greater than 5 million Btu per hour (MMBtu/hr).

Compliance Date: December 1, 2008 

Boilers, steam generators, and process heaters with a rated heat input greater 

than 5.0 MMBtu/hr must meet NOx emission limits ranging from 6 to 15 parts per 

million by volume (ppmv) corrected to 3% oxygen (O2) on a dry basis if gaseous 

fueled and 40 ppmv if liquid fueled (with few exceptions). Exceptions include, but 

are not limited to, refinery units with heat input between 5 MMBtu/hr and 

110 MMBtu/hr. These units have gaseous fueled NOx compliance levels ranging 

from 25 to 30 ppmv, depending on size. 

Rule: 4307 – Boilers, Steam Generators, and Process Heaters – 

2.0 MMBtu/hr to 5.0 MMBtu/hr

Last Revised: April 20, 2006 

Applicability: This rule applies to any gaseous fuel or liquid fuel fired 

boiler, steam generator, or process heater with a total rated 

heat input of 2.0 MMBtu/hr up to and including 

5.0 MMBtu/hr. 

Compliance Date: July 1, 2009 

Boilers, steam generators, and process heaters with a total rated heat input of 

2.0 MMBtu/hr up to and including 5.0 MMBtu/hr must meet NOx emission limits 

of either 30 or 40 ppmv corrected to 3% O2 depending on fuel type. 

Rule: 4308 – Boilers, Steam Generators, and Process Heaters - 

0.075 MMBtu/hr To 2.0 MMBtu/hr

Last Revised: October 20, 2005 

Applicability: This rule applies to any person who supplies, sells, offers for 

sale, installs, or solicits the installation of any new small 

boiler, steam generator, process heater or water heater with 

a rated heat input capacity greater than or equal to 

0.075 MMBtu/hr and up to but not including 2.0 MMBtu/hr. 

Compliance Date: January 1, 2007 
November 6, 2007 16

Boilers, steam generators, process heaters, and water heaters with a total rated 

heat input of greater than 0.075 MMBtu/hr but less than 2.0 MMBtu/hr must meet 

NOx emission limits of either 0.036 lb/MMBtu (30 ppmv) or 0.093 lb/MMBtu 

depending on size. For the same size unit, South Coast has a NOx compliance 

level of 20 ppmv. 

The District’s 2007 Ozone Plan commits to evaluate NOx reduction opportunities 

for boilers, steam generators, and process heaters (Control Measures S-COM-1 

Large Boilers, S-COM-2 Medium Boilers, and S-COM-9 Residential Water 

Heaters) through rule amendments to be completed by the first quarter of 2009. 

In conjunction with S-COM-1, Rule 4306 is currently undergoing the amendment 

process and a draft rule (dated October 30, 2007) has been publicly released. If 

the District adopts the proposed amendments, effective June 1, 2011 natural 

gas-fired boilers will be required to meet a NOx limit ranging from 5 ppmv to 

30 ppmv depending on size of the boiler and annual heat input. The proposed 

limits reflect recent BACT determinations made by District staff, and would be the 

most stringent limits in the State. Oilfield boilers and refinery boilers are included 

in the emission limit requirements. 

In conjunction with S-COM-2, Rule 4307 is also undergoing amendments. The 

draft rule (dated October 16, 2007) has been publicly released. The proposed 

amendments include removing the oilfield boiler and school boiler exemptions by 

July 1, 2015. This will increase the stringency of the rule; however, considering 

the cost-effectiveness and availability of control technology for emission units in 

this category, District staff should consider requiring oilfield boilers to comply with 

the emission limits identified in Draft Rule 4307, Table 1, sooner than 

July 1, 2015. 

Staff identified the following differences between San Joaquin Valley District 

rules and other district rules addressing similar equipment. These differences 

are not considered significant from an emission reduction standpoint. 

• District Rule 2020 exempts boilers with heat input rates less than 

5.0 MMBtu/hr from permit requirements. El Dorado County Air Quality 

Management District rule exempt boilers with heat input rates less than 

3.0 MMBtu/hr. VCAPCD has a heat input exemption threshold of 

1.0 MMBtu/hr. 

• Draft Rule 4306, Section 4.2.1 exempts natural gas boilers from emission 

limits during a maximum of 48 hours per year of testing and maintenance 

operations using fuels other than Public Utilities Commission quality 

natural gas (i.e., a back-up fuel). SCAQMD Rule 1135 contains a similar 

exemption for electric power generating boilers which exempts 24 hours 

per year of such operation. 
November 6, 2007 17

• District Rule 4308, Boilers, Steam Generators and Process Heaters from 

0.075 to 2.0 MMBtu/hr, does not apply to existing equipment. SCAQMD 

Rule 1146.2 establishes a compliance schedule for existing equipment. 

Solid Fuel Fired Boilers, 

Process Heaters and Steam Generators

Existing San Joaquin Valley District Control Rule(s) 

Rule: 4352 – Solid Fuel Fired Boilers, Steam Generators, and 

Process Heaters

Last Revised: May 18, 2006 

Applicability: This rule applies to any boiler, steam generator, or process 

heater fired on solid fuel. Heat may be supplied by liquid or 

gaseous fuels for start-ups, shutdowns, and during other 

flame stabilization periods, as deemed necessary by the 

owner/operator.

Compliance Date: January 1, 2007 

Municipal solid waste boilers have a NOx emission limit of 200 ppmv, corrected 

to 12% CO2. All other boilers, steam generators, and process heaters fueled by 

biomass must meet a NOx emission limit of 115 ppmv corrected to 3% O2. Units 

operated at stationary sources that have a potential to emit less than 10 tons per 

year of NOx are exempt from the provisions of this rule. 

The District’s 2007 Ozone Plan addresses solid fuel boilers in Control Measure 

S-COM-4, which recommends re-examining the achievability of more stringent 

emission limits. 

Stationary Gas Turbines

Existing San Joaquin Valley District Control Rule(s) 

Rule: 4703 – Stationary Gas Turbines

Last Revised: September 20, 2007 

Applicability: The provisions of this rule apply to all stationary gas turbine 

systems, which are subject to District permitting 

requirements, and with ratings equal to or greater than 

0.3 megawatt (MW) or a maximum heat input rating of more 

than 3.0 MMBtu/hr.

Compliance Date: January 1, 2012 

By January 1, 2012, all turbines must meet Tier 3 NOx compliance limits. All 

liquid-fueled turbines must meet a NOx emission limit of 25 ppmv at 15% O2, with 

one exception; liquid-fueled turbines with a maximum heat input rating greater 

than 10 MW and permitted to operate less than 200 hr/year must maintain NOx 

limits of 42 ppmv. 
November 6, 2007 18

Gaseous fueled turbines must maintain NOx limits anywhere between 

5-12 ppmv, based on classification rating and length of annual operation. 

Simple-cycle turbines rated at greater than 10 MW and permitted for operation 

less than 200 hours/year must not exceed NOx levels of 25 ppmv. Turbines 

rated at less than 0.3 MW are exempt from the provisions of this rule. 

The District has amended its turbine rule several times in recent years, and it is 

currently the most stringent in the State. With the exception of small or low-use 

turbines, the Tier 3 NOx requirements are close to emission levels currently 

required as BACT in California for gaseous fuel-fired units. 

In the future, the District could explore bringing more non-electrical generating 

turbines under regulatory control by, for example, lowering the applicability 

thresholds of the rule to greater than or equal to 0.2 MW or maximum heat input 

rating of greater than 2.0 MMBtu/hr. For dual fuel and non-gaseous fuel units, 

District staff could also explore the NOx reduction potential and feasibility of 

requiring that only natural gas be used as a primary turbine fuel unless there is a 

natural gas curtailment. However, District staff should consider keeping the rule 

sufficiently flexible so the use of alternative/renewable fuels is not prohibited due 

to potential greenhouse gas benefits if there is no concurrent backsliding on NOx 

emissions. 

Stationary Internal Combustion Engines

Existing San Joaquin Valley District Control Rule(s) 

Rule: 4702 – Internal Combustion Engines – Phase 2

Last Revised: January 18, 2007 

Applicability: This rule applies to any internal combustion engine with a 

rated brake horsepower (bhp) greater than 50 bhp.

Compliance Date: January 1, 2015 to January 1, 2020 – Compression Ignition 

January 1, 2010 – Agricultural Spark Ignition 

Spark-ignited internal combustion engines (ICE) not used exclusively in 

agricultural operations must maintain NOx levels between 25 and 75 ppmv 

(corrected to 15% O2 on a dry basis). Spark-ignited ICEs used exclusively in 

agricultural operations must meet NOx emission limits between 90 and 

150 ppmv, depending on engine type. 

Certified compression-ignition engines must comply with EPA Tier 3 or Tier 4 

requirements. Non-certified compression-ignition engines greater than 500 bhp 

and operating more than 100 hours per year must meet a NOx emission limit of 

80 ppmv. 

Some exemptions include ICEs rated at less than 50 bhp, ICEs used to propel 

implements of husbandry, ICEs used to power mobile agricultural equipment, 
November 6, 2007 19

and ICEs that operate no greater than 200 hours per calendar year (with few 

exceptions). 

The District’s 2007 Ozone Plan addresses internal combustion engines in Control 

Measure S-COM-6. No schedule is included to strengthen Rule 4702. District 

staff recommended accelerating replacement of engines with electric motors and 

lowering the applicability threshold below 50 bhp. ARB staff encourages the 

District to accelerate electrification where possible. 

Glass Production Furnaces

Existing San Joaquin Valley District Control Rule(s) 

Rule: 4354 – Glass Melting Furnaces 

Last Revised: August 17, 2006 

Applicability: The provisions of this rule shall apply to any glass-melting 

furnace. 

Compliance Date: March 31, 2008 

By March 31, 2008, all glass melting furnaces must meet Tier 2 NOx compliance 

limits. Container glass or fiberglass furnaces must meet a NOx emission limit of 

4.0 lb/ton of glass pulled on a block 24-hour average. Flat glass furnaces must 

meet a NOx emission limit of 9.2 lb/ton of glass pulled on a block 24-hour 

average and 7.0 lb/ton of glass pulled on a rolling 30-day average. 

Glass melting furnaces with a total potential to emit, for all processes, less than 

ten (10.0) tons per year of NOx are exempt from the provisions of this rule. Also 

exempt from this rule are glass melting furnaces where all the heat is supplied by 

an electric current from electrodes submerged in the molten glass. Heat may be 

supplied by other fuels for start-up when the furnace contains no molten glass. 

Container glass/fiberglass and flat glass are not separated in the BAAQMD rule 

regulating NOx emissions from glass melting furnaces. SCAQMD Rule 1117 for 

Glass Melting Furnaces does not apply to flat glass furnaces. 

The District’s 2007 Ozone Plan commits to evaluating NOx reduction 

opportunities for glass melting operations (Control Measure S-COM-7) through a 

rule amendment to be completed by the third quarter of 2008. Rule 4354 is 

currently undergoing the amendment process and a draft rule (dated 

October 8, 2007) has been publicly released. If the District adopts its proposed 

amendments to Rule 4354, the NOx emission limit requirements (from 1.3 to 

3.7 lb NOx/ton glass pulled and effective on and after January 1, 2011 to 

coincide with expected furnace rebuild schedules) will be the most stringent in 

the State. The proposed limits reflect recent BACT determinations made by 

District staff. 
November 6, 2007 20

Dryers, Dehydrators, and Ovens

Existing San Joaquin Valley District Control Rule(s) 

Rule: 4309 – Dryers, Dehydrators, and Ovens 

Last Revised: December 15, 2005 

Applicability: This rule applies to any dryer, dehydrator, or oven that is 

fired on gaseous fuel, liquid fuel, or is fired on gaseous and 

liquid fuel sequentially, and the total rated heat input for the 

unit is 5.0 million British thermal units per hour 

(5.0 MMBtu/hr) or greater.

Compliance Date: December 1, 2008 

Dehydrators are required to use only PUC quality natural gas, except during 

natural gas curtailments. 

Concrete and asphalt plants must meet NOx emission limits of 4.3 ppmv when 

fueled by natural gas, and 12.0 ppmv for liquid fuel. 

Milk, cheese and dairy processing facilities must meet NOx emission limits of 

3.5 ppmv @ 19% O2 (36.7 ppmv @ 3% O2) if heat input is less than 20 MMBtu/hr 

and 5.3 ppmv @ 19% O2 (55.5 ppm @ 3% O2) if greater than or equal to 20 

MMBtu/hr, regardless of fuel type. All other processes must meet a NOx 

emission limit of 4.3 ppmv. 

Exemptions include any unit with less than 5.0 MMBtu/hr heat input, column-type 

or towers dryers used to dry grains, or tree nuts, units used to pre-condition 

onions or garlic prior to dehydration, smokehouses or units used for roasting, and 

units used to bake or fry foods for human consumption. 

The District’s Ozone Plan addresses dryers, dehydrators, and ovens in Control 

Measure S-COM-11, which, while not recommending any rule revisions in the 

near future, commits to re-evaluating the source category in the future. 

ARB staff conducted a search for similar rules for dryers and ovens in other 

districts, but found that other districts do not have similar source-specific rules. 

South Coast, for example, limits NOx emissions from ovens and dryers using 

only BACT requirements at the time of permitting (SCAQMD Draft 2007 Air 

Quality Management Plan, Appendix IV-A-41). SCAQMD’s 2003 BACT level for 

ovens and dryers was 30 ppm at 3% oxygen. 

The District’s existing emission limits appear to reflect the application of low-NOx 

burners. 
November 6, 2007 21

Flares

Existing San Joaquin Valley District Control Rule(s) 

Rule: 4311 – Flares 

Last Revised: June 15, 2006 

Applicability: This rule is applicable to operations involving the use of 

flares.

Compliance Date: January 1, 2008 

Ground-level flares without steam-assist must meet NOx emission limits ranging 

from 0.0952-0.5240 lb/MMBtu depending on heat release rate. Ground-level 

flares with steam-assist must meet a NOx emission limit of 0.068 lb/MMBtu. 

Flares operated in municipal solid waste landfills, flares that are subject to the 

requirements of specific federal regulation, flares that are permitted to operate 

only during emergencies, and flares that emit less than 10 tons NOx per year are 

exempt from the emission limits in the rule. 

The District’s 2007 Ozone Plan addresses flares in S-IND-21. The 

2007 Ozone Plan suggests that most of the NOx from flares is a result of the 

natural gas pilot flame that remains on at all times. District staff recommended 

evaluating the effect of flare minimization plans and considering the incorporation 

of requirements in Rule 4311 that will minimize flaring events. BAAQMD 

Rule 12-12 prohibits flaring except for emergencies or unless it is consistent with 

an approved flare minimization plan. 

Other Opportunities 

Composting and Biosolids

Controlling emissions from the composting of green waste and biosolids will be 

critical as these industries seek to expand into the Valley. District staff estimated 

that ROG emissions from composting operations will be nearly 75 tpd by 2017. 

Much of the waste being treated is not generated within the Valley. The 

economic setting of the composting industry in California often results in this 

waste being transported into the Valley, as real estate values and regulation in 

other regions make local handling cost prohibitive. At the same time, State law 

requires that California communities divert waste from our landfills – a 

requirement that green waste and biosolid composting is especially well suited to 

address. 

The District has committed to reducing emissions from composting of green 

waste and biosolids through the use of best management practices. In order to 

balance California’s waste disposal and air quality needs, handling green waste 

and biosolids should be addressed through a multi-regional, multi-media 
November 6, 2007 22

approach, rather than through regulations which are intended to transfer the 

wastes, and the associated air quality impacts, into yet another region. 

Dairies

Senate Bill 700 (SB 700, Florez, 2003), required ARB to develop a definition for 

large confined animal facilities (CAFs.) Also as part of SB 700, the District is 

required is required to permit large CAFs and adopt a rule requiring an emissions 

mitigation plan. ARB adopted a CAF definition in 2005. The District required 

operators of CAFs to submit mitigation plans starting in June 2006. And the 

District is now lowering its existing threshold for dairy mitigation to one-half the 

ARB definition of a large CAF. 

Cattle and poultry operations are the main types of CAFs in California. In 

addition to ozone precursor and particulate emissions, dairy manure also emits 

greenhouse gases including methane, carbon dioxide, and nitrous oxide. 

The California Global Warming Solutions Act of 2006 (AB 32), creates a 

comprehensive, multi-year program to reduce greenhouse gas emissions in 

California. 

The consideration of manure management strategies is part of the State's 

strategy for achieving greenhouse gas reductions under AB 32. ARB staff will 

conduct a series of public consultation meetings to solicit stakeholder input on 

potential greenhouse gas emission reduction strategies for manure management 

activities. Reducing methane emission from livestock operations has significant 

potential to help California meet its 2020 greenhouse gas target. Potential ROG 

reductions from these strategies could produce ozone co-benefits. The climate 

change scoping plan required next year under AB 32 will serve as a mechanism 

for moving forward on identifying further dairy emission reduction opportunities. 

Burning

SB 705 requires the District to revise rules that regulate the open burning of 

agricultural crops and waste. SB 705 prohibits the issuance of any permit to burn 

certain categories of agricultural waste in the San Joaquin Valley Air Basin 

commencing on specific dates for each category. SB 705 allows the limited 

continuation of burning of agricultural waste, conditioned on the presence of 

disease. 

Recent District rule revisions have included limited postponements to the phase 

out of agricultural burning, as allowed under SB 705. The District included a 

sunset date, as a part of the rule, after which the postponement expires. Once 

these postponements have expired, agricultural burning would only be 

conditionally allowed for diseased crops. The District staff should continue to 

work with the agricultural industry, as well as those industries providing 

alternatives to open field burning of agricultural waste, to ensure that upon 

expiration of the postponement, viable alternatives exist. 
November 6, 2007 23

POTENTIAL IMPACT ON PROGRESS TOWARD ATTAINMENT 

The following table shows the potential impact on progress toward attainment of 

the federal ozone standard of the changes discussed in this report. The 

information in the table, especially as it pertains to the potential improvements to 

the on-road truck emissions estimates (inventory and truck fleet rule emission 

reductions), is draft and subject to change. This is not a revision to the 

attainment demonstration. 

The table shows that the Valley will make greater and more rapid progress 

toward attainment than was previously estimated by the air agencies. The 

remaining emission reductions needed for attainment in 2023 in the District’s 

adopted SIP is 80 tons per day (tpd) of NOx. ARB staff’s estimate today is that 

that the needed remaining emission reductions may be as low as one quarter of 

that, on the order of 20 tpd. Most importantly, ARB staff now estimates that 

progress by 2017 will be much greater than previously believed. The remaining 

excess emissions in 2017 will be only half of the previous estimate. While this 

gap can not feasibly be closed now, and 2023 remains the necessary legal 

deadline, most of what needs to be accomplished to attain the federal standard 

will be in place by 2017. 

San Joaquin Valley NOx Emissions with Strengthened SIP Commitments 

and Future Emissions Inventory Improvements 

` 

2017 2020 2023 

Baseline Emissions 362 322 295 

Natural Gas Combustion 37 38 39 

Small Boilers Rules 4307 & 4308 4 4 5 

Pending and Future 

Potential Emission 

Inventory Improvements 

(these all would reduce the 

future estimated emissions 

compared to the SIP.) 

Possible Heavy-duty Truck Inventory 

Estimate Update 44 28 17 

Strengthened ARB Reductions with 

Potential Updated On-road Truck 

Emissions Reduction Estimate Based 

on Possible Heavy-duty Truck 

Inventory Estimate Update 

61 49 45 Measure Reductions 

District Reductions 8 8 8 

Adjusted Controlled Emissions Inventory 209 193 181 

Attainment Target 160 

Remaining Emission Reduction Needs after Adoption of Strengthened 

SIP Measures and Pending and Future Potential Emissions Inventory 

Improvements 

49 33 21 
November 6, 2007 24

(This page intentionally blank.) 
Appendix A 

SUMMARY OF STRENGTHENED STATE IMPLEMENTATION PLAN 

STRATEGY 
(This page intentionally left blank.) 
November 6, 2007 Appendix A 1 

SUMMARY OF STRENGTHENED STATE IMPLEMENTATION PLAN STRATEGY 

California's State Implementation Plan (SIP) 

Revised Staff Proposal (September 27, 2007) 

Summary of Strengthened State Strategy 

Discussion of Proposed New Local, State, and Federal Actions 

At two Air Resources Board (ARB or Board) meetings in June 2007, the air quality 

challenges of meeting the federal PM2.5 standard in the South Coast and the federal 

8-hour ozone standard in the South Coast and San Joaquin Valley were discussed at 

length. At both meetings, the Board determined that there was still more work to be 

done to sufficiently meet these challenges and directed staff to collaborate with the 

respective air districts on this task. Subsequent efforts of staff and Board members 

from ARB, the South Coast and San Joaquin Valley air districts, and the Southern 

California Association of Governments (SCAG), resulted in a strengthening of 

California’s 2007 State Implementation Plan (SIP) that was adopted by the Board at its 

September 27, 2007 meeting. 

For the San Joaquin Valley, ARB staff identified additional emission reductions from 

mobile sources for inclusion in the proposed State Strategy to help attain the ozone 

standard prior to the 2023 deadline. Work also began to try to identify further emission 

reductions from stationary sources in the Valley. For the South Coast, actions were 

identified that would achieve the additional emission reductions needed by 2014 to 

reach the PM2.5 target established by the South Coast Air District. 

This section describes the strengthened State Strategy and the benefits for the 

San Joaquin Valley. 

San Joaquin Valley

At the June 14, 2007 ARB meeting in Fresno, the Board heard several hours of 

testimony indicating that more work was needed to reduce emissions in advance of a 

2023 “extreme” ozone attainment date. A primary focus was a draft report by the 

International Sustainable Systems Research Center (ISSRC), which suggested ways to 

further reduce emissions from both stationary and mobile sources in the Valley. At the 

meeting, the Board directed staff to explore what additional actions could be included in 

the SIP to further reduce emissions, including thoroughly reviewing the ISSRC report. 

The public comments also indicated that significant work must be done to reach out to 

the public and build partnerships. In response, the Board also directed staff to establish 

a task force with Valley stakeholders to evaluate ways to further reduce emissions, 

including evaluating the ISSRC proposal, and to hold a series of town hall meetings in 
November 6, 2007 Appendix A 2 

Valley communities in an effort to receive input from the public. ARB staff held town hall 

meetings in Parlier, Arvin and Merced. ARB Board Members D’Adamo and Case have 

attended these meetings to directly hear from community members. 

ARB staff held two task force meetings in August 2007 and also held a third meeting on 

September 24, 2007 focused on ARB staff’s proposed new mobile source SIP 

commitments. The next two task force meetings will focus on the stationary source 

recommendations in the ISSRC report. ARB staff will report back to the Board on the 

results of these activities at its November 15, 2007 meeting. 

The table below shows the additional actions that strengthen the mobile source portion 

of the San Joaquin Valley’s 2007 ozone SIP. 

Additional Actions to Accelerate Ozone Air Quality Progress 

in the San Joaquin Valley 

(NOx Emission Reductions – tons/day in 2017) 

Action / Measure Responsible 

Agency NOx

Enhanced Heavy-Duty Truck Measure ARB 17 

SOON Program Opt-in for Construction Equipment District/ARB 4 

Mobile Agricultural Equipment ARB 5-10 

Stationary Sources District Under 

evaluation 

Additional Reductions 26-31 

Enhanced ARB and District Actions 

ARB’s commitments for additional actions are an enhanced heavy-duty truck measure 

and a mobile agricultural equipment measure. An enhanced heavy-duty truck measure 

that will be heard by the Board in 2008, will reduce NOx emissions by 62 tons per day in 

the San Joaquin Valley in 2017 – 17 tons per day more than what was initially proposed. 

The emissions impact of the measure will be equivalent to having all model year 2006 

and older trucks meet model year 2007 emission levels by 2014. A cleaner in-use 

agricultural equipment rule will reduce 5-10 tons per day in the Valley in 2017. ARB will 

bring this measure to the Board by 2009. 

The enhanced State Strategy also includes an opt-in provision for a regional incentive 

program for off-road equipment. The Surplus Off-road Opt-in for NOx (SOON) program 

gives air districts the option of requiring older larger fleets to meet a higher level of 

control when incentive funds are available to help offset the cost of control. If the 
November 6, 2007 Appendix A 3 

San Joaquin Valley air district opts in to the SOON program, it is estimated that 

approximately four tons per day of additional NOx reductions could be realized in 2017. 

Staff will continue to evaluate local actions for increasing NOx reductions and will also 

look at additional ROG reduction opportunities, including those in the ISSRC report and 

in public testimony. Staff does not propose to submit the stationary source portion of the 

San Joaquin Valley Ozone SIP before the Task Force process is complete. 

Enhanced State Implementation Plan Commitments

The tables below show the emission reduction commitments of the adopted State 

Strategy. The enhanced State Strategy includes commitments from ARB to provide 

additional tons of NOx emissions in 2017 to accelerate ozone air quality progress in the 

San Joaquin Valley. The 2017 commitment is for a total of 88-93 tons/day of NOx 

reductions. This includes 22-27 tons per day of additional NOx reductions than the 

original proposed strategy. 

Summary of Emission Reduction Commitments – San Joaquin Valley 

(tons per day) 

Year NOx ROG Direct 

PM2.5 SOx 

2014 76 23 5 0 

2020 56 24 -- -- 

2023 46 25 -- -- 

2023 CAA 182(e)(5) 

measures 

81 1 --

 1

 -- -- 

1 The reductions of NOx and ROG from 182(e)(5) measures will be reassessed as new SIPs are developed 

and revised. 

Summary of Emission Reduction Commitments – San Joaquin Valley 

NOx Reductions to Accelerate Ozone Standard Attainment 

(tons per day) 

Year NOx 

2017 88-93 
(This page intentionally left blank.) 
Appendix B 

CALCULATION METHOD FOR AIR QUALITY PROGRESS METRIC 
(This page intentionally left blank.) 
November 5, 2007 Appendix B 1 

CALCULATION METHOD FOR AIR QUALITY PROGRESS METRIC 

This appendix provides the calculation method for the air quality progress metric used in 

the body of the report. The metric shows approximately 90 percent progress in terms of 

compliance with the federal 8-hour ozone standard by 2018. From a legal perspective, 

compliance with the standard is either yes or no for each air quality monitoring site. 

Therefore, staff considered any site for which photochemical modeling predicts moving 

from nonattainment to attainment of the standard as 100 percent improvement. Eleven 

of the eighteen sites show 100% improvement. Even the most challenging sites in the 

southern Valley show significant improvement. For example, from the table below, 

Arvin shows a 50 percent improvement relative to the predicted value above the federal 

standard on the remaining days that exceed the standard (the number days exceeding 

the standard will be substantially lower than today). Since the monitoring network is 

reasonably representative of the entire Valley, staff calculated the overall progress as 

the average percent improvement across all sites. The photochemical modeling used to 

project the 2018 concentrations is available at: 

http://eos.arb.ca.gov/eos/SIP_Modeling/cc/2018_SJV_DVs_2007-01-19.pdf

 

Observed 

Ozone Design 

Value, ppb 

Predicted Ozone Design 

Value, ppb 

Standard Exceeded 

By, ppb 

Design Value 

Improvement 

% 

Site 2006 2018 with new measures 2006 2018 2006 vs 2018 

Arvin 110 97 26 13 50% 

Bakersfield - California St. 99 85 15 1 93% 

Bakersfield - Golden Ave. 88 83 4 0 100% 

Clovis 90 83 6 0 100% 

Edison 100 89 16 5 69% 

Fresno - Drummond St. 87 84 3 0 100% 

Fresno - First St. 99 86 15 2 87% 

Fresno - Sierra Skypark 96 92 12 8 33% 

Hanford 86 77 2 0 100% 

Sequoia N.F. - Mineral King Rd 103 83 19 0 100% 

Madera 78 74 -- -- -- 

Merced 88 82 4 0 100% 

Mariposa 89 82 5 0 100% 

Oildale 96 87 12 3 75% 

Parlier 92 87 8 3 63% 

Shafter 89 79 5 0 100% 

Sequoia N.F. - Lower Kaweah 96 81 12 0 100% 

Turlock 86 80 2 0 100% 

Visalia 92 79 8 0 100% 
(This page intentionally left blank.) 
Appendix C 

TASK FORCE AND PUBLIC OUTREACH MATERIALS 
(This page intentionally left blank.) 
November 6, 2007 Appendix C 1 

TASK FORCE AND PUBLIC OUTREACH MATERIALS 

Air Resources Board Air Quality Task Force 

For the San Joaquin Valley 

Membership List 

Business/Agriculture Industry 

Jan Marie Ennenga, Executive Director 

Manufacturing Council of the Central Valley 

Paul Martin, Director of Environmental Services 

Western United Dairymen 

Les Clark, Executive Vice President 

Independent Oil Producers' Agency 

Chris Savage 

Director of Environmental and Regulatory Compliance

Roger Isom 

Vice President and Director of Technical Services 

California Cotton Ginners’ and Growers’ Association

Environmental/Community Groups 

Kim Thompson, Air Quality Director 

Fresno-Madera Medical Society 

David Lighthall, Ph.D. 

Central Valley Health Policy Institute 

Ray Leon 

Latino Environmental Advancement & Policy 

Melissa Kelly-Ortega 

Merced/Mariposa County Asthma Coalition 

Jim Lents, President 

International Sustainable Systems Research Center 

Barbara Patrick 

Great Valley Center 
November 6, 2007 Appendix C 2 

Government 

Dorene D’Adamo 

Board Member 

California Air Resources Board 

Seyed Sadredin, Executive Director/APCO 

San Joaquin Valley Unified Air Pollution Control District 

Judy Case, Supervisor 

Fresno County 
November 6, 2007 Appendix C 3 

Agenda 

ARB Air Quality Task Force for the San Joaquin Valley 

Kickoff Meeting 

San Joaquin Valley Room 

San Joaquin Valley Air Pollution Control District 

Fresno, California 

August 22, 2007 

1:00 – 5:00 pm 

1) Welcome and opening remarks 

2) Task Force member introductions 

3) ARB staff updates 

4) International Sustainable Systems Research Center preview of upcoming 

Clearing the Air report on the San Joaquin Valley 

5) Task Force discussion on further actions to reduce emissions 

 

6) Public Comments 

7) Next steps and agenda topics for the August 30th meeting 

 

 

 
November 6, 2007 Appendix C 4 

-- Draft Agenda -- 

ARB Air Quality Task Force for the San Joaquin Valley 

San Joaquin Valley Room 

San Joaquin Valley Air Pollution Control District 

Fresno, California 

August 30, 2007 

10:00 am – 2:30 pm 

1) Welcome, introductions, and opening remarks 10:00-10:10 

2) Financial incentives 10:10-10:35 

 - SJV Partnership Activities Pete Weber 

 - AG ICE Roger Isom 

3) ARB On-road Truck Fleet Rule 10:35-11:00 

 - Summary of concept and inventory work Jon Taylor

4) International Sustainable Systems Research Center 11:00-12:00 

Clearing the Air report on the San Joaquin Valley 

 - Introduction Jim Lents 

 - Mobile source control approaches Nicole Davis 

Lunch Break 12:00 – 1:00 

4) International Sustainable Systems Research Center, cont. 1:00-2:00 

 - Stationary source control approaches Alvin Valeriano 

5) Public comments 2:00-2:15 

6) Dates and agenda topics for the next Task Force Meeting 2:15-2:30 

 
November 6, 2007 Appendix C 5 

-- Draft Agenda -- 

ARB Air Quality Task Force for the San Joaquin Valley 

San Joaquin Valley Room 

San Joaquin Valley Air Pollution Control District 

1990 E. Gettysburg Avenue 

Fresno, California 93726 

Monday, September 24, 2007 

1:00 p.m. – 4:00 p.m. 

1) Welcome All 

2) Augmentation of the Mobile Source Reductions ARB Staff 

 September 21 Proposal 

 Comparison to ISSRC 

3) Operational Measures All 

 Discussion of ISSRC concepts 

 Other ideas 

4) ARB update on Air Quality Bonds Process ARB Staff 

5) Next Steps and Meeting Dates All 

 
November 6, 2007 Appendix C 6 

-- Draft Agenda -- 

ARB Air Quality Task Force for the San Joaquin Valley 

San Joaquin Valley Room 

San Joaquin Valley Air Pollution Control District 

1990 E. Gettysburg Avenue 

Fresno, California 93726 

Monday, October 29, 2007 

1:00 p.m. – 4:00 p.m. 

1) Welcome All 

2) ARB Report on: ARB Staff 

• Rulemaking Calendar for the Implementing the SIP 

• Air Quality Progress Toward State Standards 

3) Update on ARB Review of Potential Local Reductions ARB Staff 

 

4) Next Steps All 

Next Meeting 

November 7, 2007 

1:00 p.m. – 4:00 p.m. 

Merced County Administration Center 

Room 310 

2222 M Street 

Merced, CA 95340 
November 6, 2007 Appendix C 7 

 

 

 

SAN JOAQUIN VALLEY AIR QUALITY 

PARLIER COMMUNITY MEETING 

 

 

August 22, 2007, 6-8 pm

Kearney Agricultural Center 

9240 South Riverbend Avenue 

Parlier, CA 93648 

 

 

All community members are invited to discuss air quality concerns 

in the San Joaquin Valley. Attendees will have the opportunity to 

ask questions about current and future agency efforts. 

Please come and share your ideas on what more can be done.

Let your voice be heard! 

Spanish language translation will be available at this event. 

For more information, contact Patricia Rey at (916) 322-2638. 

Are you concerned about air quality 

in your community? 
November 6, 2007 Appendix C 8 

 

VENGA A LA JUNTA PARA LA 

COMUNIDAD DE PARLIER SOBRE 

LA CALIDAD DEL AIRE EN EL 

VALLE DE SAN JOAQUIN 

 

Miércoles 22 de agosto, 2007 

De 6 a 8 de la noche 

Centro Agricultural Kearney 

9240 Sur de la Avenida Riverbend 

Parlier, CA 93648

 

Se invita a todos los miembros de la comunidad a que nos 

acompañen para hablar acerca de sus preocupaciones sobre la 

calidad del aire en el Valle de San Joaquín. Todos los que asistan 

tendrán la oportunidad de hacer preguntas acerca de los corrientes 

y futuros esfuerzos que esta agencia lleva a cabo. 

Venga a compartir sus ideas sobre que mas se puede hacer 

¡Hágase oír! 

Traductores al español estarán disponibles en este evento 

Para más información, comuníquese con Patricia Rey al (916) 322-2990. 

¿Le preocupa la CALIDAD del AIRE 

en su comunidad? 
November 6, 2007 Appendix C 9 

 

 

 SAN JOAQUIN VALLEY AIR QUALITY 

 ARVIN COMMUNITY MEETING 

 

August 29, 2007, 6-8 pm 

City of Arvin Veteran’s Hall 

414 4th Street 

Arvin, CA 93203

 

 

All community members are invited to discuss air quality concerns 

in the San Joaquin Valley. Attendees will have the opportunity to 

ask questions about current and future agency efforts. 

Please come and share your ideas on what more can be done.

Let your voice be heard! 

Spanish language translation will be available at this event. 

For more information, contact Patricia Rey at (916) 322-2638. 

Are you concerned about air quality 

in your community? 
November 6, 2007 Appendix C 10 

VENGA A LA JUNTA PARA LA 

COMUNIDAD DE ARVIN SOBRE 

LA CALIDAD DEL AIRE EN EL 

VALLE DE SAN JOAQUIN 

 

Miércoles 29 de agosto, 2007 

De 6 a 8 de la noche 

Sala de Veteranos de la Ciudad de Arvin 

414 Calle 4a

Arvin, CA 93203

 

 

Se invita a todos los miembros de la comunidad a que nos 

acompañen para hablar acerca de sus preocupaciones sobre la 

calidad del aire en el Valle de San Joaquín. Todos los que asistan 

tendrán la oportunidad de hacer preguntas acerca de los corrientes 

y futuros esfuerzos que esta agencia lleva a cabo. 

Venga a compartir sus ideas sobre que mas se puede hacer 

¡Hágase oír! 

Traductores al español estarán disponibles en este evento 

Para más información, comuníquese con Patricia Rey al (916) 322-2990. 

¿Le preocupa la CALIDAD del AIRE 

en su comunidad? 
November 6, 2007 Appendix C 11 

 

 

 

SAN JOAQUIN VALLEY AIR QUALITY 

MERCED COMMUNITY MEETING 

 

 

November 7, 2007, 6-8 pm 

Tenaya Middle School 

760 W. 8th Street 

(corner of 8th and N Streets) 

Merced, CA 95341 

 

All community members are invited to discuss air quality concerns 

in the San Joaquin Valley. Attendees will have the opportunity to 

ask questions about current and future agency efforts. 

Please come and share your ideas on what more can be done.

Let your voice be heard! 

Spanish language translation will be available at this event. 

For more information, contact Patricia Rey at (916) 322-2638. 

Are you concerned about air quality 

in your community? 
November 6, 2007 Appendix C 12 

 

VENGA A LA JUNTA PARA LA 

COMUNIDAD DE MERCED SOBRE 

LA CALIDAD DEL AIRE EN EL 

VALLE DE SAN JOAQUIN 

 

Miércoles 7 de noviembre, 2007 

De 6 a 8 de la noche 

Tenaya Middle School 

760 West 8th Street 

(esquina de las calles 8 y la N) 

Merced, CA 95341 

 

Se invita a todos los miembros de la comunidad a que nos 

acompañen para hablar acerca de sus preocupaciones sobre la 

calidad del aire en el Valle de San Joaquín. Todos los que asistan 

tendrán la oportunidad de hacer preguntas acerca de los corrientes 

y futuros esfuerzos que esta agencia lleva a cabo. 

Venga a compartir sus ideas sobre que mas se puede hacer 

¡Hágase oír! 

Traductores al español estarán disponibles en este evento 

Para más información, comuníquese con Patricia Rey al (916) 322-2990.

¿Le preocupa la CALIDAD del AIRE 

en su comunidad? 
November 6, 2007 Appendix C 13