1

From: Yura, Elizabeth@ARB [eyura@arb.ca.gov]

Sent: Monday, June 10, 2013 4:39 PM

To: Steckel, Andrew

Cc: samir.sheikh@valleyair.org; Jessi Fierro; lnegrete@arb.ca.gov; Gregor, Sam@ARB; Velasco, 

Patricia@ARB; Vanderspek, Sylvia@ARB; Perez, Idalia; Kay, Rynda; Drake, Kerry; Hong, 

Jeanhee; Zabel, Allan; Magliano, Karen@ARB

Subject: RE: Draft Deliberative - Prop 1B Documentation

Attachments: Rule 9610 Integrity Element Support- Prop 1B Guidelines Draft 6-06-13.docx

Hello Andy, 

We’ve modified the Prop 1B document to address your questions below, and also to address Idalia’s questions regarding

truck reuse and the scrappage of vehicles under the Prop 1B program. If you have any questions, please let me know. 

Thanks, 

Elizabeth Yura

Manager, Goods Movement Programs Section

Ph: (916) 327-2953 

Fax: (916) 327-5621

From: Steckel, Andrew [mailto:Steckel.Andrew@epa.gov] 

Sent: Wednesday, June 05, 2013 11:17 AM 

To: Magliano, Karen@ARB; Yura, Elizabeth@ARB 

Cc: samir.sheikh@valleyair.org; Jessi Fierro; Negrete, Lucina@ARB; Gregor, Sam@ARB; Velasco, Patricia@ARB; 

Vanderspek, Sylvia@ARB; Perez, Idalia; Kay, Rynda; Drake, Kerry; Hong, Jeanhee; Zabel, Allan 

Subject: Draft Deliberative - Prop 1B Documentation 

Karen & Elizabeth, 

Thank you for the very helpful information regarding Prop 1B. Two additional requests: 

1. We did not review the information with respect to the 2008 and 2010 versions of these Prop 1B 

guidelines. Please clarify in the final version of this document whether the same 2013 Prop 1B citations 

apply to the 2008 and 2010 versions and, if they do not, then provide any additional needed information

regarding the older versions. 

2. The information provided indicates that the documents that describe the emissions calculations 

methodologies are publicly available on the Program website, but the Guidelines do not contain the 

specific emission factors, assumptions and equations used in each calculator. The “Directions” 

document for the Benefits Calculator states that the emission factors were obtained from the On-Road 

Heavy-Duty Diesel Vehicles (In-Use) Regulation, but we could not find the information. Please provide 

the information needed to understand how these factors were derived. 

Thanks again, 

Andy 

From: Magliano, Karen@ARB [mailto:kmaglian@arb.ca.gov] 

Sent: Friday, May 31, 2013 3:19 PM 
2

To: Steckel, Andrew; Perez, Idalia; Drake, Kerry; samir.sheikh@valleyair.org; Jessi Fierro 

Cc: Vanderspek, Sylvia@ARB; Yura, Elizabeth@ARB; Velasco, Patricia@ARB; lnegrete@arb.ca.gov; Gregor, 

Sam@ARB 

Subject: Draft Deliberative - Prop 1B Documentation 

Andy: 

Attached is documentation prepared by Elizabeth Yura on how the Prop 1B guidelines meet the incentive 

program integrity elements. Please let us know if you have any follow-up questions. 

Regards, Karen 
Draft – Do Not Cite or Distribute – For Discussion Purposes Only 

(revised June 6, 2013) 

San Joaquin Valley Air Pollution Control District Proposed Rule 9610 

Responses to U.S. EPA’s Request to Address “Integrity Elements” in the 

Proposition 1B: Goods Movement Emission Reduction Program Guidelines 

1 

Introduction

The information provided below reflects the May 21, 2013 version of the San Joaquin Valley Air 

Pollution Control District Proposed Rule 9610. Under this version of the proposed rule, only 

heavy duty diesel truck repower, replacement or retrofit incentive projects are being included for 

the Air Resources Board’s (ARB’s) Proposition 1B Goods Movement Emission Reduction 

Program (Proposition 1B). The proposed rule does not include any projects covered by truck 

reuse programs. The references to address U.S. EPA’s “integrity elements” are limited to those 

that pertain to the heavy duty diesel truck projects. References include the applicable page 

numbers from three versions of the Proposition 1B Guidelines (2013, 2010 and 2008, 

respectively). 

SURPLUS 

Integrity Element Background

Emission reductions used to meet air quality attainment requirements are surplus if they are not 

otherwise relied on in air quality-related programs related to the SIP, SIP-related requirements, 

other State air quality programs adopted but not in the SIP, a consent decree, or Federal rules that 

focus on reducing criteria pollutants or their precursors. Provided below are details on how the 

Proposition 1B Program Guidelines (Guidelines) ensure that the emission reductions are not 

required by any regulation, the baseline equipment was being used and operated within the state, 

and that project benefits are not already accounted for in future-year inventories. 

Proposition 1B Program Requirements

The California statute that established the Proposition 1B Program states that funding shall be 

used for emission reductions not otherwise required by law or regulation, including existing 

regulations that are incorporated into a SIP (California Health and Safety Code Sections 39625-

39627.5). As a result, when developing the Guidelines, ARB staff used current and upcoming 

regulatory compliance dates to determine which projects are eligible and the period during which 

projects can claim “early or extra” emission reductions. The Guidelines also include procedures 

to ensure that reductions are not claimed for projects impacted by future ARB regulations. To 

quantify emission reductions, the Guidelines state that ARB staff shall develop “Projects 

Benefits Calculators” which are publicly available on the Program website. ARB regularly 

updates these calculators to incorporate updated emissions inventory methodologies and to 

reflect upcoming regulatory deadlines that may occur during the project life. 

Projects must be installed and in operation prior to any compliance date (from one to three years, 

depending on the category) and cannot be used to demonstrate fleet compliance for a set period 

of time (from one to three years, depending on the category). SIP inventories reflect compliance 

with already adopted regulations. As part of the SIP development and/or revision process, ARB 

reviews the Proposition 1B project mix to ensure that the amount of emission reductions credited 

to the program are not included in the future year inventories, including review of fleet turnover 
Draft – Do Not Cite or Distribute – For Discussion Purposes Only 

(revised June 6, 2013) 

San Joaquin Valley Air Pollution Control District Proposed Rule 9610 

Responses to U.S. EPA’s Request to Address “Integrity Elements” in the 

Proposition 1B: Goods Movement Emission Reduction Program Guidelines 

2 

and equipment lifetime assumptions that are specific to the future year inventory used in each 

individual attainment demonstration. 

For all projects, the Guidelines require that local agencies and equipment owners document and 

verify that the old equipment was in use and was used in the geographic area of interest for at 

least 24 months prior to application. 

Applicable References in Proposition 1B Guidelines – “Surplus” Element

1. Emission Reductions Must Be Early or Extra 

· Funding must be used for emission reductions not otherwise required by law or 

regulation. (2013 Guidelines: Chapter I. Overview, Section B. Authority, pg.3. 

2010 Guidelines: pg.3. 2008 Guidelines: pg.2) 

· Local agencies must ensure that funding is used for emission reductions not otherwise 

required by law or regulation – both existing and upcoming. (2013 Guidelines: 

Chapter III. Local Agency Project Proposal, Section B. Legal and Program 

Restrictions, pp.60-62. 2010 Guidelines: pp.57-59. 2008 Guidelines: pp.47-49) 

· The Guidelines specifically list trucks that are ineligible because regulations are fully 

in effect and it’s no longer possible to achieve early or extra reductions. 

(2013 Guidelines: Appendix A, Project Specifications for Heavy Duty Diesel Trucks, 

pg.A-1. 2010 Guidelines: pp.A-1 to A-6. 2008 Guidelines: pp.A-1 to A-3 and B-1 to 

B-5) 

· Operational Deadlines and the Allowable Use of Equipment for Fleet Compliance are 

publicly available on the Program website. 

(http://www.arb.ca.gov/bonds/gmbond/gmbond.htm) 

2. Quantifying Emission Reductions 

· ARB must develop “Projects Benefits Calculators” to determine emission reductions. 

(Chapter II, ARB Program Administration, Section C.2 Project Specifications and 

Emissions, Quantifying project benefits, pg.28. 2010 Guidelines: pg.26 

2008 Guidelines: pg.20) 

· “Projects Benefits Calculators” and documents that describe the emissions 

calculations methodologies are publicly available on the Program website, but the 

Guidelines do not contain the specific emission factors or other factors used in each 

calculator. (http://www.arb.ca.gov/bonds/gmbond/gmbond.htm) 

· For truck projects, the current “Projects Benefits Calculator” uses emission factors 

obtained from the On-Road Heavy Duty Diesel Vehicles (In-Use) Regulation. These 

factors are publicly available on the following ARB website: 

"The Truck and Bus Regulation, The Drayage Truck Regulation and The TractorTrailer Greenhouse Gas Regulation Amendments, Background Materials on Air 

Emissions, Health Impacts, and Economic Impacts", AB1085 documentation, 

Emission Inventory Database (Nov. 17, 2010), Emission Rates tab: 

http://www.arb.ca.gov/msprog/onrdiesel/ab1085compliance.htm
Draft – Do Not Cite or Distribute – For Discussion Purposes Only 

(revised June 6, 2013) 

San Joaquin Valley Air Pollution Control District Proposed Rule 9610 

Responses to U.S. EPA’s Request to Address “Integrity Elements” in the 

Proposition 1B: Goods Movement Emission Reduction Program Guidelines 

3 

http://www.arb.ca.gov/msprog/onrdiesel/1085/truck%20and%20bus%20rule_ei_1112

_2010_viewlink_fixed.zip

· Additional information on the emission inventory methodology for the current truck 

“Projects Benefits Calculator” is publicly available on the ARB website in the 

following two Technical Support Documents: 

2008 Technical Support Document

Staff Report: Initial Statement of Reasons for Proposed Rulemaking, Proposed 

Regulation for In-Use On-Road Diesel Vehicles, Technical Support Document, 

Appendix G, Emissions Inventory Methodology and Results. October 2008: 

http://www.arb.ca.gov/regact/2008/truckbus08/truckbus08.htm

http://www.arb.ca.gov/regact/2008/truckbus08/appg.pdf

2010 Technical Support Document

Staff Report: Initial Statement of Reasons for Proposed Rulemaking, Proposed 

Amendments to the Truck and Bus Regulation, the Drayage Truck Regulation and the 

Tractor-Trailer Greenhouse Gas Regulation, Appendix G, Emissions Analysis 

Methodology and Results, Medium-Heavy Duty Diesel Trucks, Heavy-Heavy Duty 

Diesel Trucks, and Regulated Bus Categories. October 2010: 

http://www.arb.ca.gov/regact/2010/truckbus10/truckbus10.htm

http://www.arb.ca.gov/regact/2010/truckbus10/truckbusappg.pdf

· For truck projects under the 2008 Guidelines, the “Projects Benefits Calculator” 

(dated March 2008) uses emission factors from EMFAC2007 V2.3 (Nov. 1 2006). 

ARB staff used the output from EMFAC2007 to get statewide annual average 

emissions from heavy heavy-duty diesel trucks and the associated vehicle miles 

travelled (VMT). To determine average emission factors by engine model year, staff 

divided emissions by VMT to get emission factors in grams per mile. The 

EMFAC2007 model is publicly available on the following ARB website: 

http://www.arb.ca.gov/msei/documentation.htm

3. Project Life 

· The Guidelines specify the allowable project life for each category. (Appendix A, 

Project Specifications for Heavy Duty Diesel Trucks, pp.A-3 to A-5. 

2010 Guidelines: pp.A-3 to A-6. 2008 Guidelines: pp.A-1 to A-3 and B-1 to B-5) 

· Local agencies shall not modify the project life options. (Chapter III, Local Agency 

Project Proposal, Section B. Legal and Program Restrictions, pg.64. 

2010 Guidelines: pg.60. 2008 Guidelines: pg.55) 

4. Activity Data 

· Local agencies must verify project eligibility, including verification of registration 

documents and vehicle miles travelled (VMT) data to confirm California operation 

for the past two years. (Chapter IV. Local Agency Project Implementation, Section 
Draft – Do Not Cite or Distribute – For Discussion Purposes Only 

(revised June 6, 2013) 

San Joaquin Valley Air Pollution Control District Proposed Rule 9610 

Responses to U.S. EPA’s Request to Address “Integrity Elements” in the 

Proposition 1B: Goods Movement Emission Reduction Program Guidelines 

4 

A.5. Evaluation and GMOD entry of equipment project applications, pp.80-81. 

2010 Guidelines: pg.76. 2008 Guidelines: pp.64-65) 

· Equipment owners must provide documentation of activity data for the old equipment 

during the past two years including: verification of California registration, at least 

75% California operation, vehicle miles travelled, percentage of time in each trade 

corridor. (Appendix A, Project Specifications for Heavy Duty Diesel Trucks, 

pp.A-1, A-9, A-10. 2010 Guidelines: pp.A-1, A-9, A-10. 2008 Guidelines: pp.A-1, 

A-5 to A-7, B-1, B-7 to B-10) 

· Local agencies must verify that old equipment is operational during a pre-inspection. 

(Chapter IV. Local Agency Project Implementation, Section A. Project 

Implementation Requirements, pg.90. 2010 Guidelines: pp.82-83. 

2008 Guidelines: pp.68-69) 

· Equipment owners must commit to operate at least 90% in California and at least 

50% within the four designated trade corridors, during the entire project life. 

(Appendix A, Project Specifications for Heavy Duty Diesel Trucks, pg.A-2. 

2010 Guidelines: pg.A-2. 2008 Guidelines: pp.A-1 to A-3 and B-1 to B-5) 

QUANTIFIABLE 

Integrity Element Background

In order for emissions and emission reductions to be attributed to an Economic Incentive 

Program (EIP), they must be quantifiable which means they can be reliably measured or 

determined and be replicated. Provided below are details on how the Proposition 1B Program 

quantifies emission reductions and ensures that the calculation methodologies are publicly 

available, current and accurate. Also addressed are the Proposition 1B requirements to ensure 

that data provided by the applicant is sufficient to accurately determine emission reductions. 

Proposition 1B Program Requirements

The Guidelines state that ARB shall develop and make available on the Proposition 1B website 

“Projects Benefits Calculators” that quantify emission reductions and cost-effectiveness. These 

calculators are publicly available on the website, along with documents that describe the 

emissions calculations methodologies, but the Guidelines do not include the specific emission 

factors used in each calculator. Emission reductions estimates rely on the data and emissions 

factors inherent in ARB’s emissions inventory, adopted regulations, and Executive Orders, as 

well as State and Federal regulatory emission standards. Baseline emissions from old equipment 

are calculated based on data provided by the applicant and verified by the local agencies. Future 

emissions for new equipment are based on emission factors for equipment meeting the emissions 

standards specified in the Guidelines. Both emissions benefits and cost-effectiveness contribute 

to a competitive ranking, based on a formula contained in the Guidelines. To ensure that the 

expected emission reductions actually occur in the geographic area of interest and within 
Draft – Do Not Cite or Distribute – For Discussion Purposes Only 

(revised June 6, 2013) 

San Joaquin Valley Air Pollution Control District Proposed Rule 9610 

Responses to U.S. EPA’s Request to Address “Integrity Elements” in the 

Proposition 1B: Goods Movement Emission Reduction Program Guidelines 

5 

designated time frames, the Guidelines require ARB and local agencies to conduct ongoing 

project evaluations. 

Applicable References in Proposition 1B Guidelines – “Quantifiable” Element

1. Emission Reductions Calculation Methods 

· ARB must develop “Projects Benefits Calculators”. (Chapter II, ARB Program 

Administration, Section C.2 Project Specifications and Emissions, Quantifying 

project benefits, pg.28. 2010 Guidelines: pg.26. 2008 Guidelines: pg.20) 

· “Projects Benefits Calculators” and documents that describe the emissions 

calculations methodologies are publicly available on the Program website, but the 

Guidelines do not contain the specific emission factors or other factors used in each 

calculator. (http://www.arb.ca.gov/bonds/gmbond/gmbond.htm) 

(Please see additional references for emission factors under the “Surplus” section.) 

2. Activity Data to Support Emission Reductions Calculations 

· Equipment owners must provide documentation of activity data for the old equipment 

during the past two years including: verification of California registration, at least 

75% California operation, vehicle miles travelled, percentage of time in each trade 

corridor. (Appendix A, Project Specifications for Heavy Duty Diesel Trucks, pp.A-1, 

A-9, A-10. 2010 Guidelines: pp.A-1, A-9, A-10. 2008 Guidelines: pp.A-1, A-5, A-6, 

B-1, B-7 to B-10) 

3. Requirements for New Equipment 

· All diesel engines for repower or replacement projects must be certified by ARB 

Executive Order to meet 2010 emissions standards. The Guidelines do not allow 

funding for uncertified or unverified diesel engines. (Appendix A, Project 

Specifications for Heavy Duty Diesel Trucks, pg.A-2. 2010 Guidelines: pp.A-1 to 

A-3. 2008 Guidelines: pp.A-1 to A-3 and B-1 to B-4) 

4. Evaluations to Ensure Emission Reductions Occur 

· ARB staff must conduct ongoing evaluations of local agency projects, including a 

review of project records to ensure consistency with emission reduction goals 

(Chapter II. ARB Program Administration, Section F.4. Ongoing evaluations, pg.48. 

2010 Guidelines: pp.45-46. 2008 Guidelines: pp.35-36) 

· Local agencies must evaluate projects on an ongoing basis to meet accountability 

requirements. Evaluation efforts include a variety of measures (e.g., site inspections; 

reviews of reports, records, activity logs, etc.) (Chapter IV. Local Agency Project 

Implementation, Section D. Ongoing Local Agency Evaluation of Equipment 

Projects, pg.107. 2010 Guidelines: pg.96. 2008 Guidelines: pg.86) 
Draft – Do Not Cite or Distribute – For Discussion Purposes Only 

(revised June 6, 2013) 

San Joaquin Valley Air Pollution Control District Proposed Rule 9610 

Responses to U.S. EPA’s Request to Address “Integrity Elements” in the 

Proposition 1B: Goods Movement Emission Reduction Program Guidelines 

6 

ENFORCEABLE 

Integrity Element Background

Emission reductions are enforceable if there are legally binding grant agreements and contracts 

that define the requirements and the parties liable for fulfilling the requirements. Provided below 

are details on how the Guidelines require enforceable contracts, recordkeeping, reporting, and 

project inspections to ensure that contract requirements are met and that equipment is consistent 

with contract specifications. 

Proposition 1B Program Requirements

The Guidelines require the local agency and the equipment owner to enter into contract for the 

life of the project. To ensure that all surplus benefits occur during the life of the project, the 

contract life is either equal to or greater than the number of years before action is required under 

applicable ARB regulations. The Guidelines also require ARB to execute grant agreements with 

local agencies. Under these grant agreements, the local agencies authorize ARB to inspect 

equipment projects and obtain access to records. For both project contracts and grant 

agreements, the Guidelines define actions that constitute contract non-performance and remedies 

for non-performance. 

Applicable References in Proposition 1B Guidelines – “Enforceable” Element

1. Grant Agreements and Project Contracts 

· ARB’s funding decisions shall become legally enforceable through executed grant 

agreements between ARB and the selected local agencies. The grant agreements 

must contain enforcement provisions that authorize ARB to inspect equipment 

projects and give ARB access to evaluate or audit Program records. (Chapter II, ARB 

Program Administration, Section E.10 ARB Process to Award Funds to Local and 

State Agencies, Local agency grant agreement, pp.38-41. 2010 Guidelines: pp.35-38. 

2008 Guidelines: pp.29-32) 

· The Guidelines describe actions that constitute local agency non-performance 

(e.g., funding ineligible projects) and remedies for local agency non-performance 

(e.g., recapture of funds). (Chapter II, ARB Program Administration, Section F.7. 

Local agency non-performance, pp.55-58. 2010 Guidelines: pp.52-55. 

2008 Guidelines: pp.42-45) 

· Funding commitments shall become legally enforceable only through executed 

contracts between the local agency and equipment owner. The Guidelines require 

certain provisions in each contract, including enforcement and remedies for 

non-performance. (Chapter IV. Local Agency Project Implementation, Section A.11. 

Project Implementation Requirements, Equipment Project Contracts, pp.91-94. 

2010 Guidelines: pp.83-86. 2008 Guidelines: pp.69-72) 
Draft – Do Not Cite or Distribute – For Discussion Purposes Only 

(revised June 6, 2013) 

San Joaquin Valley Air Pollution Control District Proposed Rule 9610 

Responses to U.S. EPA’s Request to Address “Integrity Elements” in the 

Proposition 1B: Goods Movement Emission Reduction Program Guidelines 

7 

· Equipment owners shall sign a legally binding contract with the local agency 

including project milestones and completion deadlines. (Appendix A, Project 

Specifications for Heavy Duty Diesel Trucks, pg.A-1. 2010 Guidelines: pg.A-2. 

2008 Guidelines: pp.A-1 to A-3 and B-1 to B-5) 

· The Guidelines describe actions that constitute contract non-performance (e.g., failure 

to comply with Guidelines) and remedies for non-performance (e.g., recovery of 

funds). (Chapter VI. General Equipment Project Requirements, Section K. 

Equipment Project Non-Performance pg.122. 2010 Guidelines: pp.107-108. 

2008 Guidelines: pp.93-94) 

2. Recordkeeping and Reporting 

· Equipment owners must comply with recordkeeping, reporting, and Proposition 1B 

review or fiscal audit requirements, for the duration of the project life. The 

Guidelines also specify recordkeeping requirements that extend beyond the duration 

of the project. (Appendix A, Project Specifications for Heavy Duty Diesel Trucks, 

pp.A-1, A-16. 2010 Guidelines: pp.A-2, A-18. 2008 Guidelines: pp.A-1 to A-4 and 

B-1 to B-6) 

· Equipment owners must submit annual reports that include certification of the 

required California-based VMT and certification that at least 50 percent of travel 

occurred within the four trade corridors. (Appendix A, Project Specifications for 

Heavy Duty Diesel Trucks, pg.A-17. 2010 Guidelines: pg.A-18. 2008 Guidelines: 

pp.A-4, B-6) 

· Local agencies must submit status reports for all projects (quarterly, semi-annually, 

after project completion). (Chapter IV. Local Agency Project Implementation, 

Section E. Local Agency Reporting Requirements pp.107-109. 

2010 Guidelines: pp.96-98. 2008 Guidelines: pp.86-89) 

3. Inspections 

· Local agencies must conduct and document pre-inspections after projects have been 

identified for funding. However, the Guidelines state that pre-inspections are not 

required if the existing equipment was previously funded by the Proposition 1B 

Program within two years of the project application date. (Chapter IV. Local Agency 

Project Implementation, Section A.10. Project Implementation Requirements, 

Equipment project pre-inspections, pg.90. 2010 Guidelines: pp.82-83. 

2008 Guidelines: pp.68-69) 

· Local agencies must conduct and document project post-inspections on all funded 

projects. (Chapter IV. Local Agency Project Implementation, Section A.16. Project 

Implementation Requirements, Equipment project post-inspections, pg.99. 

2010 Guidelines: pp.90-91. 2008 Guidelines: pp.77-80) 

· The Project Specifications provide detailed requirements on timing and data 

verification for post-inspections. (Appendix A, Project Specifications for Heavy 

Duty Diesel Trucks, pg.A-15. 2010 Guidelines: pp.A-16, A-17. 

2008 Guidelines: pp.77-80) 
Draft – Do Not Cite or Distribute – For Discussion Purposes Only 

(revised June 6, 2013) 

San Joaquin Valley Air Pollution Control District Proposed Rule 9610 

Responses to U.S. EPA’s Request to Address “Integrity Elements” in the 

Proposition 1B: Goods Movement Emission Reduction Program Guidelines 

8 

· For both pre- and post-inspections, the Guidelines specify the items that must be 

verified during the inspection to ensure that program information is consistent with 

actual equipment (e.g., odometer readings, VINs, serial numbers, filter retrofits, etc.) 

(see references noted above) 

PERMANENT 

Integrity Element Background

Emission reductions used to meet air quality attainment requirements must be permanent. 

Provided below are details on how the Guidelines ensure that funded projects achieve emission 

reductions for the life of the project in the geographic area specified in the contract, and that 

these projects are monitored during the project life. 

Proposition 1B Program Truck Requirements

To ensure that emission reductions are permanent, the Guidelines require that old equipment be 

scrapped (permanently removed from service) for truck repower and replacement projects. 

Local agencies are responsible for ensuring that scrappage occurs and the Guidelines specify the 

applicable procedures and documentation requirements to verify scrapped engines. By 

comparing data from the pre-inspection with information provided after scrappage, local 

agencies confirm that the correct engine was destroyed. To further ensure that emission 

reductions are permanent, the Guidelines require ARB and local agencies to conduct ongoing 

project evaluations. 

The Guidelines do include a provision for truck reuse programs as a potential alternative to 

scrapping a truck, under limited circumstances. However, the San Joaquin Valley’s proposed 

rule does not include any projects covered by truck reuse programs, so this provision is not 

applicable for the purposes of the proposed rule. 

To verify that emission reductions are occurring in the geographic area of interest, the Guidelines 

require recordkeeping and reporting for local agencies and equipment owners, during the entire 

project life. 
Draft – Do Not Cite or Distribute – For Discussion Purposes Only 

(revised June 6, 2013) 

San Joaquin Valley Air Pollution Control District Proposed Rule 9610 

Responses to U.S. EPA’s Request to Address “Integrity Elements” in the 

Proposition 1B: Goods Movement Emission Reduction Program Guidelines 

9 

Applicable References in Proposition 1B Guidelines – “Permanent” Element

1. Scrap Requirements 

· Local agencies shall ensure that old equipment is scrapped and they must obtain 

digital documentation to verify the scrappage, including photos of the destroyed 

engine. Engine blocks shall be punctured and physically destroyed in such a manner 

to eliminate the possibility of future operation. Dismantlers are required to be 

licensed by the Department of Motor Vehicles (DMV). (Chapter IV. Local Agency 

Project Implementation, Section A.14. Project Implementation Requirements, 

Equipment project scrap requirements, pp.97-98. 2010 Guidelines: pp.88-89. 

2008 Guidelines: pp.73-75) 

· The Guidelines contain details on scrappage time frames and documentation 

requirements. For both repower and replacement projects, the dismantler shall 

provide proof of scrappage to the local agency. For replacement projects, the 

dismantler shall also provide a copy of the form submitted to DMV to permanently 

remove the vehicle from service (REG 488C, REG 42). (Appendix A, Project 

Specifications for Heavy Duty Diesel Trucks, pp.A-13, A-14. 

2010 Guidelines: pp.A-13 to A-15. 2008 Guidelines: pp.73-75) 

· Local agencies shall be responsible for collecting all necessary information prior to 

scrap/disposal activities (e.g., during pre-inspection). All information collected and 

recorded must be readily accessible to verify that scrap and disposal procedures were 

conducted for the appropriate engine. (Chapter IV. Local Agency Project 

Implementation, Section A.14. Project Implementation Requirements, Equipment 

project scrap requirements, pp.97-98. 2010 Guidelines: pp.88-89. 

2008 Guidelines: pp.73-75) 

2. Evaluations to Ensure Scrappage Occurs 

· ARB staff must conduct ongoing evaluations of local agency projects, including a 

review of project records to ensure consistency with emission reduction goals. 

(Chapter II. ARB Program Administration, Section F.4. Ongoing evaluations, pg.48. 

2010 Guidelines: pp.45-46. 2008 Guidelines: pp.35-36) 

· Local agencies must evaluate projects on an ongoing basis to meet accountability 

requirements. Evaluation efforts include a variety of measures (e.g., site inspections; 

reviews of reports, records, activity logs, etc.) (Chapter IV. Local Agency Project 

Implementation, Section D. Ongoing Local Agency Evaluation of Equipment 

Projects, pg.107. 2010 Guidelines: pg.96. 2008 Guidelines: pg.86) 
Draft – Do Not Cite or Distribute – For Discussion Purposes Only 

(revised June 6, 2013) 

San Joaquin Valley Air Pollution Control District Proposed Rule 9610 

Responses to U.S. EPA’s Request to Address “Integrity Elements” in the 

Proposition 1B: Goods Movement Emission Reduction Program Guidelines 

10 

3. Recordkeeping and Reporting to Verify Emission Reductions in Geographic Area of Interest 

· Equipment owners must comply with recordkeeping, reporting, and Program review 

or fiscal audit requirements, for the duration of the project life. The Guidelines also 

specify recordkeeping requirements that extend beyond the duration of the project. 

(Appendix A, Project Specifications for Heavy Duty Diesel Trucks, pp.A-1, A-16. 

2010 Guidelines: pp.A-2, A-18. 2008 Guidelines: pp.A-1 to A-4 and B-1 to B-6) 

· Equipment owners must submit annual reports that include certification of the 

required California-based VMT and certification that at least 50 percent of travel 

occurred within the four trade corridors. (Appendix A, Project Specifications for 

Heavy Duty Diesel Trucks, pg.A-17. 2010 Guidelines: pg.A-18. 

2008 Guidelines: pp.A-4, B-6) 

· Local agencies must submit status reports for all projects (quarterly, semi-annually, 

after project completion). (Chapter IV. Local Agency Project Implementation, 

Section E. Local Agency Reporting Requirements pp.107-109. 

2010 Guidelines: pp.96-98. 2008 Guidelines: pp.86-89)