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 C alifornia Air Resources Board and approved for publication. Approval does not si gnify that the contents necessarily reflect the views and policies of the A ir Resources Board, nor does the mention of trade names or commercial products c onstitute 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 Stati onary Sources Improving the Effectiveness of the District’s BACT Program Evaluation of San Joaquin Valley District Rule Stri ngency 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 PL AN

STRATEGY

B. CALCULATION METHOD FOR AIR QUALITY PROGRESS MET RIC

C. TASK FORCE AND PUBLIC OUTREACH MATERIALS

(Additional Resource Material available under separ ate 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 Joaqu in 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 de signed to pursue

additional actions that would further accelerate cl ean air progress. This report provides ARB staff’s summary of what has been accom plished in that process and what it means in terms of the Valley’s ozone SI P.

On September 27, 2007, ARB approved a strengthened State Strategy for the SIP that is expected to result in approximately a 9 0 percent improvement in air quality over the next ten years relative to complia nce 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 2 023, most of what needs to be done will be accomplished by 2017.

Nonetheless, many Valley residents want assurance t hat air agencies are doing all they can to improve air quality as quickly as p ossible. Now that ARB’s portion of the SIP has been strengthened, ARB staff has foc used 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 eval uated 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 action s 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 wo uld have shown the South Coast District with the State’s most stringent rule s, setting the benchmark for stationary source control. The picture today looks very different. Since early this decade, the Valley District has set aggressive rule making targets in its SIPs for ozone and particulate matter. As a result, its exi sting rules together with those under development now are on par with the South Coa st’s. Information about

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

The challenge that remains will require development and application of new technologies, increased efficiency across all secto rs of the economy, land use and transportation policies that foster sustainable growth, and actions by Valley residents to reduce the air quality impacts of thei r daily activities. Incentive funds will help achieve early reductions as new regulator y requirements phase in. ARB staff has proposed several recommendations that would support such efforts. These recommendations are intended to supp lement the approved SIP, and if successful, could later be quantified and cr edited towards attainment.November 6, 2007 iv

Conclusions and Recommendations

The San Joaquin Valley‘s Air Pollution Control Dist rict (District), along with local cities, counties, and transportation agencies, all have important roles to play in reducing air pollution as the region continues to g row. The District’s rules currently meet State and federal SIP stringency req uirements. However, as technology advances, additional cost-effective appl ications 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 i ts cost-effectiveness thresholds for Best Available Control Technology (BACT) for ne w air pollution sources

consistent with other air districts’ thresholds. Th is would expand the universe of potential control technologies the District cons iders in the permitting

process.

• The District should widen its search for cutting-e dge technologies by looking beyond the Valley for new control techniques. This includes looking at other California air district control technology database s as well as looking elsewhere in the country and internationally.

• In assessing the applicability of technologies, th e District should consider the feasibility of technology transfers from one source type to another.

• The District should continue to look for opportuni ties to expand the use of technologies identified in the International Sustai nable Systems Research Center (ISSRC) draft August 2007 report. Continuin g efforts to electrify agricultural pumps is an example. ARB staff suppor ts a partnership with the District and agriculture industry to bring about th e 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 techno logy development.

• The District should continue its local task force as a means to identify ways to speed progress and should expand its purview to inc lude 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 eff ort to design strategies to reduce greenhouse gas emissions from manure managem ent and any other strategies that may have a co-benefit of reducing o zone forming pollutants.

Clean Air Days

• The District should encourage actions by Valley re sidents and businesses to reduce emissions on days with high ozone levels. T he 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 sup port land use and transportation decisions that foster sustainable gr owth. The District should take a leadership role and engage with other local agencies to bring air quality concerns more broadly into regional decisio n 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 projec ts that provide real, costeffective emissions reductions.

• The District should continue to work with ARB to m aximize the use of incentive funds to achieve early emission reduction s in the Valley. The District is already very active in the public proce ss for obtaining Proposition 1B bond monies, and the California Partnership for the San Joaquin Valley has been an important voice in indentifying the nee d 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, an d construction and agricultural equipment. To follow up in September’s actions, AR B 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 w ill 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 equip ment 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 pub lic workshops throughout the Valley on rulemaking, bond funding, climate cha nge, and other issues as they come forward.

Technology Advancement

• ARB staff is working with US EPA on a New Technolo gy Forum to be held in the San Joaquin Valley in 2008. The goal is to sho wcase new technologies that will provide many of the new near-term emissio n reductions in the Valley’s ozone SIP, as well as potential longer-ter m technology

advancements.

Public Education

• ARB staff will hold a public education forum in th e Valley in 2008 focused on the science of air pollution in the Valley. ARB st aff will develop community oriented presentations on the science underlying Ca lifornia’s effort to improve air quality in the San Joaquin Valley. The forum i s planned for UC Merced to facilitate academic participation.

ARB SIP Progress Reports

• ARB staff will report annually to the Air Resource s 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 updat e at District Board meetings on topics of interest to the Board.November 6, 2007 1

INTRODUCTION

Background

The federally required 2007 Ozone Attainment Plan f or 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 st ationary sources (e.g., industrial and commercial facilities) is the respon sibility of the District. The mobile source element of the plan is the responsibi lity of the ARB. These two components, combined with transportation strategies and required technical elements, comprise the SIP for a region. In June 2 007 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, t he 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 2 017 from new ARB measures were increased by 50 percent compared to the origin al 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 Stra tegy is included as an appendix to this report.

With ARB’s portion of the SIP strengthened, ARB sta ff has focused on the District’s SIP element to answer the basic question s: do the District’s rules and SIP measures meet State and federal legal requireme nts for rule stringency and what actions should the District take to speed air quality progress?

Staff’s review focused primarily on the District ru les and measures for controlling oxides of nitrogen (NOx). Air quality science indi cates that NOx reductions are relatively more beneficial for reducing ozone than are reductions of reactive organic gases, or ROG, and the Valley’s NOx reducti on needs are large. Staff looked at the District’s adopted rules and SIP meas ures for limiting emissions from already existing sources and at the District’s New Source Review program

that looks at emissions from new sources. Staff al so examined the SIP inventory to assess the impact of recent inventory improvemen t work on progress toward

attainment.

Public Process – Task Force and Community Meetings

In June 2007, at the ARB meeting to consider the Di strict’s element of the SIP, the Board directed staff to conduct a public proces s to pursue additional actions that would further accelerate clean air progress. Two ARB Board members agreed to oversee the process. As part of the proc ess, the Board directed staffNovember 6, 2007 2

to establish a task force to engage Valley environm ental, business, and government leaders in the process and to hold commu nity 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 advo cates, 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 fou r times to date, with a fifth meeting scheduled for November 7, 2007. The task f orce meetings all provide opportunity for public comment. The meetings agend as are included in Appendix D.

In addition, community meetings were convened in ea ch of the three Valley subregions – south, central and north. In August 2 007, ARB staff held community meetings in Parlier and Arvin. On Novemb er 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 p rovide feedback to ARB staff and the Board. Spanish translation services are pr ovided.

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 sourc e 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 con version 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 sourc es and District rules and SIP measures. At that meeting, the task force members requested that ARB staff

broaden its review to include additional District r ules. This report includes a review of those additional rules. ARB staff will p resent a summary of this report at the fifth task force meeting, scheduled for Nove mber 7, 2007.November 6, 2007 3

EMISSIONS INVENTORY DESCRIPTION AND REVIEW

An estimate of the emissions in a region is the fou ndation of a SIP. Emission inventories undergo constant improvement as new inf ormation is gathered about sources and emission rates. However, to support SI P 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. T his inventory snapshot is used in the photochemical modeling to set overall e mission reduction targets and

to estimate the emission reductions from control me asures. As SIPs are implemented and updated, new inventory information is taken into account.

Since the SIP inventory was finalized in November 2 006, District and ARB staffs have continued to work on inventory improvements. Even though the SIP inventory is set, understanding the potential impac t of those improvements on emission reduction estimates and overall progress t oward attainment is critical to assessing the question of accelerating progress. T here 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 fr om data other than from permits, i.e., total natural gas consumption in the Valley.

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

District rules.

3. A future ARB update of emissions from diesel tru cks.

4. A future ARB update of emissions from agricultur al equipment (mostly tractors).

Stationary Source Emissions

ARB staff reviewed the emissions inventory for sour ces under District authority, in order to verify that the District has current em ission control rules. The table

below identifies the NOx emission sources in the Va lley and the applicable emission control regulation. In a few instances, s uch as chemical and plastic manufacturing or metal plating and coating operatio ns, the District controls emissions primarily for ROG or particulate matter ( PM) benefits, but there may be small NOx emissions reported. These are so noted b elow.November 6, 2007 4 NOx Emission Sources and Applicable Emission Contro l 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

Subtota l * 11.2

Boilers, Process Heaters, and

Steam Generators 0.1 4306-4308 Petroleum Refining And 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 conventio ns. ** A discussion of the improvements to the methodol ogy 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 emi ssions from NOx emissions from industrial equipment for which natural gas con sumption or emissions are not reported for individual sources. In short, these a re sources too small to fall intoNovember 6, 2007 6

the district permitting program. Without permit da ta, emissions from these

sources must be estimated from other information.

The emissions for these so called “unspecified” man ufacturing and industrial natural gas consumption sources in the 2007 Ozone P lan come from an estimate developed in the early 1990s. This estimate was ca rried forward into the current inventory. District staff recently reviewed this c ategory and could find no documentation substantiating the existing estimate. Therefore, District staff developed a new methodology for estimating emission s 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. A RB staff believes the methodology is a technically sound approach for est imating NOx emissions from these types of sources.

Emissions Inventory Revisions for Unspecified Manufacturing and Industrial Natural Ga s 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 conventio ns.

The revised emission estimation methodologies use 2 005 natural gas deliveries reported to the California Energy Commission (CEC), beyond that used by permitted stationary sources in the Valley, to esti mate the NOx emissions from combustion of that natural gas. For emission estim ation purposes, this natural gas is assumed to be combusted in a small uncontrol led 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, spec ifically rules 4307 and 4308 that govern emissions from boilers, steam generators, an d process heaters. These types of devices are used in many industries as evi denced 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 func tion of the existing level of

control at affected sources and the emission reduct ions associated with the technologies underlying the rule.November 6, 2007 7

District staff believes that their current inventor y methodology does not correctly apply control factors to many of the equipment unit s that are covered by District rules 4307 and 4308. Consequently, based on prelim inary draft estimates 1

, District staff believes that future emissions from these sources are

overestimated. The table below shows the draft re vised estimate for the benefits of these rules compared to the estimate the Distric t 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 ti me to include the final data in future SIP emission inventories. Like ARB’s potent ial mobile source inventory improvements, these anticipated changes will not im pact 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 p rocess 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 previ ous year indicates that the average age of trucks operating in the Valley may b e younger than ARB staff has previously estimated. To the extent that trucks op erating in the Valley are newer than previously thought, a revised diesel truck inv entory 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 e mission 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 rev ised draft assessment of the emissions benefits of rules 4307 and 4308 – regulating emissi ons from boilers, process heaters and steam generators rated between 75,000 British thermal uni ts (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 th e impacts of any diesel truck inventory changes. ARB staff has presented this in formation here to help provide a general understanding of how future inventory cha nges may impact progress

toward attainment of the ozone standard in the Vall ey.

Potential Changes to On-road Heavy Duty Truck Emiss ion 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 Hea vy Duty Truck Emission Estimates in the San Joaquin Valley on ARB ’s 2007 State Strategy Commitment for Cleaner In-Use Heavy-duty T rucks

(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 sup port of upcoming rule development for the cleanup of in-use agricultural equipment. The Board committed to develop a measure to clean up agricult ural equipment as part of the State Strategy adopted in September 2007.

That effort is in its very first stages, and ARB st aff does not yet have enough information to provide a preliminary estimate of th e potential changes to the inventory that may result. Depending on the relati onships that are identified between such factors as useful life, activity by ag e and horsepower, and age distribution, future estimates could be either larg er or smaller than the current

estimate.November 6, 2007 9

REVIEW OF DISTRICT RULES AND MEASURES

State and Federal Technology Requirements for Stati onary Sources

In California, each of the local air districts has rules governing existing stationary sources. These rules are known as prohibitory rule s. They include requirements for emission limits, testing, recordkeeping, and re porting. 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 ad dress specific equipment, such as a turbine, a boiler, or an internal combustion e ngine.

Prohibitory rule emission limitations reflect estab lished emission control technologies that can be feasibly added to existing sources. The most stringent of these technologies are referred to as Best Avail able Retrofit Control Technology (BARCT). In addition to BARCT, federal law requires nonattainment areas to implement Reasonably Available Control Tec hnology (RACT) at large stationary sources.

In addition to district prohibitory rules that appl y to existing sources, there are rules that apply to new or modified stationary sour ces. These are referred to as the New Source Review (NSR) program. The NSR progr am 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 ensur e that the equipment they are installing will not emit air pollutants at leve ls greater than those of similar new facilities. These limits are at least as stringen t 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 proo f that the emission levels have been achieved in practice. District staff is also expected to conduct a broad search (even internationally, at times) for technol ogies that have been demonstrated through testing on similar types of st ationary sources to reduce

emissions to the lowest levels.

Once identified, the cost of the identified technol ogy is compared to the air

district’s BACT cost-effectiveness threshold. If t he 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 con trol 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 technol ogies is in the design phase of a new or modified stationary source. As enginee rs are designing the equipment and processes, they have the most flexibi lity to integrate the technology into the system to ensure the emission t echnology can achieve its maximum control efficiency. Integration costs are typically less as well.

As technologies advance, BACT emission levels are s ubject to continuous improvement. Further, this improvement ultimately manifests in more stringent prohibitory rule levels and lower BARCT emission le vels. 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-fu eled boilers that emitted NOx at 30 parts per million levels were previously considered BACT, and later were considered BARCT. Since then, BACT has advanc ed 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 th e 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 con ditions. BACT serves as the proving ground for air districts to evaluate the me rits and applicability of new technologies to a range of sources.

The ISSRC report recommends, for a number of differ ent types of stationary equipment and facilities, modifying prohibitory rul es 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 l evels in practice, and recommends a more exhaustive search of examples ach ieved in practice. If a technology that reduces levels of NOx from solid fu el boilers to 40 ppm is found, it would be most appropriately applied in the Valle y 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 d riving technology and the stringency of prohibitory rules, ARB reviewed the D istrict’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 whi ch the Valley District could strengthen its BACT program.

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

for BACT. The District has not raised its BACT cos t-effectiveness thresholds for ozone precursors since 1989, and they are subst antially below those of other districts of similar or better air quality st atus. The District is currently proposing to modify its NOx cost-effectiveness thre sholds so that they exceed those of SCAQMD, Bay Area Air Quality Management Di strict (BAAQMD), Ventura Air Pollution Control District (VCAPCD), an d San Diego Air Pollution Control District (SDAPCD). The table below compare s BACT costeffectiveness thresholds used by various districts.

California Air District BACT Cost-Effectiveness Thr esholds

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

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

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

SCAQMD b $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 200 8.

b Thresholds represent 2003 values. SCAQMD’s policy states that this figure should be adjusted to the latest Marshall and Swift Equipment Cost Ind ex published monthly in Chemical Engineering

.November 6, 2007 12

• The Valley District uses only its own BACT Clearin ghouse to make BACT determinations, unless there are classes and catego ries of equipment not contained in the Clearinghouse. Conducting a broad er technology search would help District staff become more aware of tech nology advancements in other jurisdictions, encourage the advancement of e mission 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 Distri ct currently requires that the “type of business where the emission units are util ized must be the same.” 2

CAPCOA/ARB Guidance on Achieved in Practice BACT De terminations does not include business type as part of the criteria f or achieved-in-practice BACT

determinations. ARB staff believes that business t ype, in itself, does not warrant establishment of a different class or categ ory of source unless unique operational or technical issues justify alternative emission levels.

• The District should continue to look for opportuni ties to expand the use of the technologies identified in the ISSRC report, includ ing electrification and SCR when making BACT determinations.

Evaluation of San Joaquin Valley District Rule Stri ngency

A snapshot of rule stringency taken ten years ago w ould have shown the South Coast District with the State’s most stringent rule s, setting the benchmark for stationary source control. San Joaquin Valley Dist rict would have been seen lagging behind. The picture today looks very diffe rent. While the South Coast is still pushing the limits of stringency, the San Joa quin 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 tab les below identify recent rules the District has adopted that limit ozone precursor emissions. As a result, its existing rules, together with those under developme nt 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-l ine at: http://www.valleyair.org/policies_per/Policies/APR% 201305.pdfNovember 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 Burnin g 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 12/1 4/2006 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

8/17/2006 4703 Stationary Gas Turbines

9/20/2007

4901 Wood Burning Fireplaces and Wood Burning Heate rs 7/17/2003

4905 Natural Gas Fired, Fan-type, Residential Central

Furnaces 10/20/2005November 6, 2007 14 Recent District ROG Control Actions

Rule Description Amendment

Dates

4403

4409

4451

4452

4455 Components at Natural Gas Production Facilities, Ch emical

Plants, and Petroleum Refineries 4/20/2005

4565 Biosolid, Animal Manure and Poultry Litter Ope rations 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 Tank s 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

5/16/2002 4661 Organic Solvents

9/20/2007

4/19/2001

12/20/2001 4662 Organic Solvent Degreasing Operations

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 iden tified where the San Joaquin Valley’s District rules differ from those for simil ar sources in other air districts. These types of differences are typical. It might b e possible to squeeze additional reductions from some sources through small incremen tal changes to emission limits, exemption levels, etc. The feasibility of these types of changes usually boils down to cost on an individual source basis, s ince the additional reductionsNovember 6, 2007 15

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

new SIP reductions the additional increment of cont rol 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 fue l or liquid fuel fired

boiler, steam generator, or process heater with a t otal rated heat input greater than 5 million Btu per hour (MMB tu/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 ran ging from 6 to 15 parts per million by volume (ppmv) corrected to 3% oxygen (O 2 ) on a dry basis if gaseous fueled and 40 ppmv if liquid fueled (with few excep tions). 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 fue l or liquid fuel fired

boiler, steam generator, or process heater with a t otal 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% O 2 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 he ater with a rated heat input capacity greater than or equal t o 0.075 MMBtu/hr and up to but not including 2.0 MMBt u/hr. Compliance Date: January 1, 2007November 6, 2007 16

Boilers, steam generators, process heaters, and wat er 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 pp mv) or 0.093 lb/MMBtu depending on size. For the same size unit, South C oast 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) h as been publicly released. If the District adopts the proposed amendments, effect ive June 1, 2011 natural gas-fired boilers will be required to meet a NOx li mit 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 D istrict staff, and would be the most stringent limits in the State. Oilfield boile rs and refinery boilers are included in the emission limit requirements.

In conjunction with S-COM-2, Rule 4307 is also unde rgoing amendments. The draft rule (dated October 16, 2007) has been public ly 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 requi ring 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 e quipment. These differences are not considered significant from an emission red uction standpoint.

• District Rule 2020 exempts boilers with heat input rates less than 5.0 MMBtu/hr from permit requirements. El Dorado C ounty Air Quality Management District rule exempt boilers with heat i nput rates less than 3.0 MMBtu/hr. VCAPCD has a heat input exemption th reshold 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 tes ting and maintenance operations using fuels other than Public Utilities Commission quality natural gas (i.e., a back-up fuel). SCAQMD Rule 11 35 contains a similar exemption for electric power generating boilers whi ch 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 e quipment. SCAQMD Rule 1146.2 establishes a compliance schedule for e xisting 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 Genera tors, and

Process Heaters Last Revised: May 18, 2006 Applicability: This rule applies to any boiler, ste am 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 l imit of 200 ppmv, corrected

to 12% CO 2 . All other boilers, steam generators, and process heaters fueled by biomass must meet a NOx emission limit of 115 ppmv corrected to 3% O 2 . Units operated at stationary sources that have a potentia l 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 achievab ility 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 N Ox compliance limits. All liquid-fueled turbines must meet a NOx emission lim it of 25 ppmv at 15% O 2 , with one exception; liquid-fueled turbines with a maximu m heat input rating greater than 10 MW and permitted to operate less than 200 h r/year must maintain NOx limits of 42 ppmv.November 6, 2007 18

Gaseous fueled turbines must maintain NOx limits an ywhere between 5-12 ppmv, based on classification rating and lengt h of annual operation. Simple-cycle turbines rated at greater than 10 MW a nd 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 provi sions of this rule.

The District has amended its turbine rule several t imes in recent years, and it is currently the most stringent in the State. With th e 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-fir ed 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 primar y turbine fuel unless there is a natural gas curtailment. However, District staff s hould consider keeping the rule sufficiently flexible so the use of alternative/ren ewable 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 co mbustion 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 be tween 25 and 75 ppmv (corrected to 15% O 2 on a dry basis). Spark-ignited ICEs used exclusiv ely in agricultural operations must meet NOx emission limi ts 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 e ngines greater than 500 bhp and operating more than 100 hours per year must mee t 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 c ombustion engines in Control Measure S-COM-6. No schedule is included to streng then Rule 4702. District staff recommended accelerating replacement of engin es with electric motors and lowering the applicability threshold below 50 bhp. ARB staff encourages the District to accelerate electrification where possib le.

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 ap ply 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 mus t meet a NOx emission limit of 4.0 lb/ton of glass pulled on a block 24-hour avera ge. Flat glass furnaces must meet a NOx emission limit of 9.2 lb/ton of glass pu lled 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 em it, 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 wh ere all the heat is supplied by an electric current from electrodes submerged in th e molten glass. Heat may be supplied by other fuels for start-up when the furna ce contains no molten glass.

Container glass/fiberglass and flat glass are not s eparated in the BAAQMD rule regulating NOx emissions from glass melting furnace s. SCAQMD Rule 1117 for Glass Melting Furnaces does not apply to flat glass furnaces.

The District’s 2007 Ozone Plan commits to evaluatin g 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 dr aft rule (dated October 8, 2007) has been publicly released. If th e District adopts its proposed amendments to Rule 4354, the NOx emission limit req uirements (from 1.3 to 3.7 lb NOx/ton glass pulled and effective on and af ter January 1, 2011 to coincide with expected furnace rebuild schedules) w ill 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, dehy drator, 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 na tural 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 fue l.

Milk, cheese and dairy processing facilities must m eet NOx emission limits of 3.5 ppmv @ 19% O 2 (36.7 ppmv @ 3% O 2 ) if heat input is less than 20 MMBtu/hr and 5.3 ppmv @ 19% O 2 (55.5 ppm @ 3% O 2 ) if greater than or equal to 20 MMBtu/hr, regardless of fuel type. All other proce sses must meet a NOx emission limit of 4.3 ppmv.

Exemptions include any unit with less than 5.0 MMBt u/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 consumpti on.

The District’s Ozone Plan addresses dryers, dehydra tors, 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 ca tegory 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 ha ve similar source-specific rules. South Coast, for example, limits NOx emissions from ovens and dryers using only BACT requirements at the time of permitting (S CAQMD 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 r eflect 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 operation s 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 relea se rate. Ground-level

flares with steam-assist must meet a NOx emission l imit 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 time s. District staff recommended evaluating the effect of flare minimization plans a nd considering the incorporation of requirements in Rule 4311 that will minimize fla ring 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 th e 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 wi thin the Valley. The economic setting of the composting industry in Cali fornia often results in this waste being transported into the Valley, as real es tate values and regulation in other regions make local handling cost prohibitive. At the same time, State law requires that California communities divert waste f rom our landfills – a requirement that green waste and biosolid compostin g is especially well suited to

address.

The District has committed to reducing emissions fr om composting of green waste and biosolids through the use of best managem ent practices. In order to balance California’s waste disposal and air quality needs, handling green waste and biosolids should be addressed through a multi-r egional, multi-mediaNovember 6, 2007 22

approach, rather than through regulations which are intended to transfer the wastes, and the associated air quality impacts, int o yet another region.

Dairies

Senate Bill 700 (SB 700, Florez, 2003), required AR B to develop a definition for large confined animal facilities (CAFs.) Also as p art 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 2 005. The District required operators of CAFs to submit mitigation plans starti ng 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 emissio ns, 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 greenho use gas emissions in

California.

The consideration of manure management strategies i s part of the State's strategy for achieving greenhouse gas reductions un der AB 32. ARB staff will conduct a series of public consultation meetings to solicit stakeholder input on potential greenhouse gas emission reduction strateg ies for manure management activities. Reducing methane emission from livesto ck operations has significant potential to help California meet its 2020 greenhou se gas target. Potential ROG reductions from these strategies could produce ozon e 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 emi ssion reduction opportunities.

Burning

SB 705 requires the District to revise rules that r egulate 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, cond itioned on the presence of

disease.

Recent District rule revisions have included limite d postponements to the phase out of agricultural burning, as allowed under SB 70 5. The District included a sunset date, as a part of the rule, after which the postponement expires. Once these postponements have expired, agricultural burn ing would only be conditionally allowed for diseased crops. The Dist rict staff should continue to work with the agricultural industry, as well as tho se 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 p rogress 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 an d 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 a nd 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 s taff’s estimate today is that that the needed remaining emission reductions may b e as low as one quarter of that, on the order of 20 tpd. Most importantly, AR B staff now estimates that progress by 2017 will be much greater than previous ly believed. The remaining excess emissions in 2017 will be only half of the p revious estimate. While this gap can not feasibly be closed now, and 2023 remain s 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 o f Strengthened SIP Measures and Pending and Future Potential Emiss ions Inventory Improvements 49 33 21November 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 S TRATEGY

California's State Implementation Plan (SIP) Revised Staff Proposal (September 27, 2007)

Summary of Strengthened State Strategy

Discussion of Proposed New Local, State, and Federa l 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 Jo aquin Valley were discussed at length. At both meetings, the Board determined tha t there was still more work to be done to sufficiently meet these challenges and dire cted 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 ai r districts, and the Southern California Association of Governments (SCAG), resul ted in a strengthening of California’s 2007 State Implementation Plan (SIP) t hat was adopted by the Board at its September 27, 2007 meeting.

For the San Joaquin Valley, ARB staff identified ad ditional 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 beg an 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 emissi on reductions needed by 2014 to reach the PM2.5 target established by the South Coa st Air District.

This section describes the strengthened State Strat egy and the benefits for the San Joaquin Valley.

San Joaquin Valley

At the June 14, 2007 ARB meeting in Fresno, the Boa rd heard several hours of testimony indicating that more work was needed to r educe emissions in advance of a 2023 “extreme” ozone attainment date. A primary fo cus was a draft report by the International Sustainable Systems Research Center ( ISSRC), which suggested ways to further reduce emissions from both stationary and m obile sources in the Valley. At the meeting, the Board directed staff to explore what a dditional actions could be included in the SIP to further reduce emissions, including thor oughly 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, th e Board also directed staff to establish a task force with Valley stakeholders to evaluate w ays to further reduce emissions, including evaluating the ISSRC proposal, and to hol d a series of town hall meetings inNovember 6, 2007 Appendix A 2

Valley communities in an effort to receive input fr om the public. ARB staff held town hall meetings in Parlier, Arvin and Merced. ARB Board M embers D’Adamo and Case have attended these meetings to directly hear from commu nity members.

ARB staff held two task force meetings in August 20 07 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 wil l report back to the Board on the results of these activities at its November 15, 200 7 meeting.

The table below shows the additional actions that s trengthen 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 enh anced heavy-duty truck measure and a mobile agricultural equipment measure. An en hanced heavy-duty truck measure that will be heard by the Board in 2008, will reduc e NOx emissions by 62 tons per day in the San Joaquin Valley in 2017 – 17 tons per day mo re than what was initially proposed. The emissions impact of the measure will be equival ent to having all model year 2006 and older trucks meet model year 2007 emission leve ls by 2014. A cleaner in-use agricultural equipment rule will reduce 5-10 tons p er 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-ro ad Opt-in for NOx (SOON) program gives air districts the option of requiring older l arger fleets to meet a higher level of control when incentive funds are available to help offset the cost of control. If theNovember 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 r eductions could be realized in 2017.

Staff will continue to evaluate local actions for i ncreasing NOx reductions and will also look at additional ROG reduction opportunities, inc luding those in the ISSRC report and in public testimony. Staff does not propose to sub mit 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 commit ments of the adopted State Strategy. The enhanced State Strategy includes com mitments from ARB to provide

additional tons of NOx emissions in 2017 to acceler ate ozone air quality progress in the San Joaquin Valley. The 2017 commitment is for a t otal of 88-93 tons/day of NOx reductions. This includes 22-27 tons per day of ad ditional NOx reductions than the original proposed strategy.

Summary of Emission Reduction Commitments – San Joa quin 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) measur es will be reassessed as new SIPs are developed

and revised.

Summary of Emission Reduction Commitments – San Joa quin Valley

NOx Reductions to Accelerate Ozone Standard Attainm ent (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 t he air quality progress metric used in the body of the report. The metric shows approxima tely 90 percent progress in terms of compliance with the federal 8-hour ozone standard b y 2018. From a legal perspective, compliance with the standard is either yes or no fo r each air quality monitoring site. Therefore, staff considered any site for which phot ochemical 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 th e predicted value above the federal standard on the remaining days that exceed the stan dard (the number days exceeding the standard will be substantially lower than today ). Since the monitoring network is reasonably representative of the entire Valley, sta ff 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 CenterNovember 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 Di strict

Judy Case, Supervisor Fresno CountyNovember 6, 2007 Appendix C 3 Agenda

ARB Air Quality Task Force for the San Joaquin Vall ey

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 Cente r preview of upcoming Clearing the Air

report on the San Joaquin Valley

5) Task Force discussion on further actions to redu ce emissions

6) Public Comments

7) Next steps and agenda topics for the August 30 th meetingNovember 6, 2007 Appendix C 4 -- Draft Agenda --

ARB Air Quality Task Force for the San Joaquin Vall ey

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 10:0 0-10:10

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 Cente r 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 Cente r, cont. 1:00-2:00 - Stationary source control approaches Alvin Valer iano

5) Public comments 2:00-2:15

6) Dates and agenda topics for the next Task Force Meeting 2:15-2:30November 6, 2007 Appendix C 5 -- Draft Agenda --

ARB Air Quality Task Force for the San Joaquin Vall ey

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 AR B 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 Sta ff

5) Next Steps and Meeting Dates AllNovember 6, 2007 Appendix C 6 -- Draft Agenda --

ARB Air Quality Task Force for the San Joaquin Vall ey

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 Reductio ns 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 95340November 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 qu ality concerns in the San Joaquin Valley. Attendees will have the opportunity to ask questions about current and future agency effor ts.

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



# Let your voice be heard!

Spanish language translation will be available at t his 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 qu e 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 4 th 

# Street Arvin, CA 93203

All community members are invited to discuss air qu ality concerns in the San Joaquin Valley. Attendees will have the opportunity to ask questions about current and future agency effor ts.

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



# Let your voice be heard!

Spanish language translation will be available at t his 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 4 a


# Arvin, CA 93203

Se invita a todos los miembros de la comunidad a qu e 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. 8 th 

# Street (corner of 8 th 

# and N Streets) Merced, CA 95341

All community members are invited to discuss air qu ality concerns in the San Joaquin Valley. Attendees will have the opportunity to ask questions about current and future agency effor ts.

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



# Let your voice be heard!

Spanish language translation will be available at t his 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 qu e 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