CHAPTER 9

CONTINGENCY MEASURES

Introduction

Level I: Contingency Measures

Level II: Further Evaluation Measures

Deleted Measures
Chapter 9 Contingency Measures

9 - 1

INTRODUCTION

In order to achieve the improvement in air quality specified in the AQMP, the control 

measures listed in the Plan must be adopted and implemented within the timeframes set 

forth. In the event that implementation of the AQMP is not providing adequate progress 

and the interim emission reduction goals have not been met, the District must take action 

to bring forward measures that are scheduled for later adoption or implementation, or to 

implement certain "contingency" control measures. These contingency measures are 

control options that could be instituted in addition to the AQMP control measures. Both 

state and federal Clean Air Acts require that district plans include contingency measures. 

In addition, several measures are identified for further evaluation which could be adopted 

in the future if found to be feasible.

A total of 24 control measures have been identified and categorized in two groups: Level 

I, or contingency measures, and Level II, or further measures which are not feasible at 

this time but will be reevaluated to determine if these measures are needed to attain state 

air quality standards or potential future federal ozone and particulates air quality 

standards. Table 9-1 lists the Level I measures and Table 9-2 lists the Level II measures. 

In addition, certain control measures from the 1994 AQMP are removed from this Plan, 

having been determined to be infeasible. The following paragraphs provide a summary 

of these control measures. A complete discussion is included in Appendix IV, Section 6.

LEVEL I: CONTINGENCY MEASURES

Level I measures are actions that can be implemented given existing statutory authority. 

Such measures would need to be developed and adopted as rules. The responsibility to 

adopt and implement the Level I measures falls on the District, ARB, and U.S. EPA. 

The measures would be implemented in the order specified in the 1997 AQMP until the 

shortfall is eliminated. A ranking of the importance of each measure relative to ozone 

and/or carbon monoxide planning requirements under the federal Clean Air Act is 

provided in Table 9-1 for the Level I measures.

LEVEL II: FURTHER EVALUATION MEASURES

Level II measures are from the 1994 AQMP and have been determined as being 

infeasible at this time, requiring further evaluation. It has been further demonstrated that 

the federal ambient air quality standards can be attained within the statutory time frames, 

without these measures, which are listed in Table 9-2. The District will continue to 

assess these measures to determine if in the aggregate these measures will be beneficial 

in attaining state air quality standards and potential future federal air quality standards.
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TABLE 9-1

Level I - Contingency Control Measures

AQMP 

Measure 

Number

Title Priority to Meet CAA 

Requirements

Responsible 

Agency

Issues

Ozone CO PM10

CTY-1 Accelerated Implementation of 

Control Measures

1 2 4 District Resource 

Availability

CTY-2 Command and Control Rules in 

Place of Educational Outreach 

Program Measures

2 3 5 District Resource 

Availability/ 

Cost 

Effectiveness

CTY-4 Enhanced Oxygenated Fuel 

Content for CO

-- 1 -- ARB Potential NOx

Emission 

Increases

CTY-12 Emission Reductions from Paved 

Roads (Curb and 

Gutter/Chemical Stabilization) 

(Formerly BCM-01 (1D & 1E))

-- -- 1 District Emissions 

Reduction 

Effectiveness

CTY 13 Further Emission Reductions 

from Construction and 

Demolition Activities (Rule 403) 

(Formerly BCM-02)

-- -- 2 District Emissions 

Reduction 

Effectiveness

CTY 14 Emission Reductions from 

Miscellaneous Sources (Weed 

Abatement) (Rule 403) (Formerly 

BCM-05)

-- -- 3 District Unquantified 

Emission 

Reductions
Chapter 9 Contingency Measures

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TABLE 9-2

Level II - Control Measures for Further Evaluation

AQMP Measure 

Number

Title Pollutant Principal 

Reason*

CMB-01 Phase II RECLAIM NOx, SOx 2

CMB-02 Emission Reductions from Combustion 

Equipment at Non-RECLAIM Sources

NOx 1,2, 3

CMB-08 Control of Emissions from Gas-Fired 

Petroleum Refinery Process Heaters

PM10 1, 2, 3

CMB-10 Emission Reductions from Glass Melting 

Furnaces (Non-RECLAIM)

NOx 3

CMB-11 Emission Reductions from Non-RECLAIM 

Incinerators

NOx 3

CTS-02A Emission Reductions from Electronic

Components Manufacturing

VOC 3

CTS-02D(1) Further Emission Reductions from Marine 

Coating Operations (Rule 1106)

VOC 3

CTS-02D(2) Further Emission Reductions from Pleasure 

Craft Coating Operations (Rule 1106.1)

VOC 3

CTS-02G Further Emission Reductions from Paper, 

Fabric, and Film Coating Operations (Rule 

1128)

VOC 3

CTS-02I(1) Further Emission Reductions from Screen 

Printing Operations (Rule 1130.1)

VOC 2,3

CTS-02J Further Emission Reductions from Wood 

Products (Rule 1136)

VOC 2,3

CTS-02K Further Emission Reductions from Aerospace 

Assembly and Component Manufacturing 

Operations (Rule 1124)

VOC 3

* 1= Not cost-effective (H&SC 40922(a))

 Not economically feasible (PRC21061.1)

2=Technically infeasible (H&SC 40922(b))

 Not technically feasible (PRC21061.1)

3=Minimal emission reduction potential (H&SC40922(b))

 Not feasible due to social impact considerations and cost of administrative burden. (PRC21061.1)

4=Low public acceptability (H&SC40922(b)

 Not feasible due to social impact considerations (PRC21061.1)
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TABLE 9-2

(Concluded)

AQMP Measure 

Number

Title Pollutant Principal 

Reason*

CTS-02L Further Emission Reductions from Motor 

Vehicle Assembly Line Coating Operations 

(Rule 1115)

VOC 3

PRC-02 Further Emission Reductions from Bakeries 

(Rule 1153)

VOC 3

PRC-05 Emission Reductions from Malt Beverage 

Production Facilities and Wine or Brandy 

Making Facilities

VOC 3

MON-02 Excessive Car Dealership Vehicle Starts VOC, CO 2

MON-04 Excessive Curb Idling VOC, CO 2

CTY-7 Stringent Emission Limits for Goods 

Movement Activities (Aircraft, Rail, and 

Marine Vessels)

All 

Pollutants

5

* 1= Not cost-effective (H&SC 40922(a))

 Not economically feasible (PRC21061.1)

2=Technically infeasible (H&SC 40922(b))

 Not technically feasible (PRC21061.1)

3=Minimal emission reduction potential (H&SC40922(b))

 Not feasible due to social impact considerations and cost of administrative burden. (PRC21061.1)

4=Low public acceptability (H&SC40922(b)

 Not feasible due to social impact considerations (PRC21061.1)

5=Economic concerns, implementation authority

There are 18 measures designated as Level II contingency control measures. The basis 

for each measure’s designation as Level II contingency is described below.

CMB-01 Phase II RECLAIM would expand the RECLAIM program to facilities with 

NOx and SOx emission reductions below 4 tons per year. Expanding the RECLAIM 

program may pose an administrative burden to the District and some of the subject 

facilities. However, the feasibility of this approach should be reevaluated in the future to 

determine if circumstances have changed.

CMB-02 This measure includes unpermitted miscellaneous combustion sources, curing 

and drying ovens, after burners, metal melting furnaces, and internal combustion engines. 

Emission reductions from non-RECLAIM combustion sources would involve the 

regulation of several tens of thousands of non-permitted emission sources. Implementing 
Chapter 9 Contingency Measures

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the control measure would require the identifying and on-going enforcement of 

thousands of currently unpermitted combustion sources at mostly small business sites. In 

addition, estimates of control technology and associated costs may be difficult due to the 

diverse nature of small businesses using these deminimus combustion equipment. For 

some devices, the control costs are also expected to be over the acceptable costeffectiveness threshold for rule development. At this time there is no technology for 

further control of the internal combustion engines which would be part of this control 

measure. Therefore, the administrative burden and lack of control technology make this 

measure infeasible at this time.

CMB-08 Control technology to reduce PM10 emissions from this source category is 

expensive and difficult to install and operate. In addition to cost and technology 

considerations, the total mass emission reductions are also small from refinery process 

heaters, due to other controls already in place to reduce NOx and SOx emissions. 

Uncertainty as to the potential emission reduction technology prevents the District from 

establishing an emission reduction factor for this control measure. It is believed also that 

the emission reductions would be minimal. This measure is, therefore, considered 

neither technically nor economically feasible at this time.

CMB-10 Glass melting furnaces not subject to the RECLAIM program represent a small 

emission source category. Potential emission reductions from this category, even with a 

high control efficiency, would be low. The emission reductions expected from this 

control measure are less than 20 pounds per day of NOx. The administrative burden of 

bringing such a rule forward, at this time, is not justifiable for the minimal emission 

reductions likely.

CMB-11 Non-RECLAIM incinerators represent a small emission source category. The 

further emission reduction potential which could be achieved by this control measure 

would, therefore, be relatively low regardless of the control efficiency factor. This 

control measure has an estimated emission reduction of 0.11 ton/day of NOx. The 

administrative burden of developing a rule is not justified at this time for such a minimal 

emission reduction.

CTS-02A Electronic component manufacturing represents a small emission source 

category. The emission reduction potential which could be achieved by this control 

measure would be relatively low regardless of the control efficiency factor. This control 

measure has an estimated emission reduction of 0.17 tons/day. The administrative 

burden of developing a rule is not justified at this time for such a minimal emission 

reduction.

CTS-02D(1) and CTS-02D(2) These measures would further regulate emissions from 

marine vessel and pleasure craft coatings respectively. The emission reductions which 

could be expected from the two control measures combined represents a total of 
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approximately 60 pounds of VOC per day. The administrative burden of developing a 

rule is not justified at this time for such a minimal emission reduction.

CTS-02G This contingency measure calls for further emission reductions from paper, 

fabric and film coating operations. The estimated emission reductions which might be 

achievable from this measure are also relatively small (340 pounds of VOC per day). 

Considering the costs of rule development and implementation that would be required of 

the District, as well as high compliance costs for minor emission reductions, 

implementation of this measure is not feasible at this time.

CTS-02I(1) The potential emission reductions which could be achieved from 

implementation of this control measure are minimal, representing a 20% reduction, when 

compared to the administrative burden of developing the rule. There is, however, 

technical uncertainty associated with the control technology to further control VOC 

emissions from screen printing operations. Therefore, it has been determined that this 

control measure is infeasible and will be delayed due to cost, and administrative burden 

relative to the minimal gain in emission reductions.

CTS-02J Due to concerns regarding the availability and feasibility of the required 

coating technology, the measure has been moved to Level II contingency status and will 

continue to be evaluated. Staff will propose further considerations when technology 

developments are found to be acceptable, cost-effective and technically feasible for this 

industry group.

CTS-02K Aerospace assembly and component manufacturing operations are already 

regulated to a great extent. The further emission reductions which would be targeted by 

this control measure are minimal, amounting to approximately 120 additional pounds of 

VOC per day. The administrative burdens of rule development are not justified at this 

time for such a minimal emission reduction. The measure has, therefore, been moved to 

a Level II contingency and will be subject to future evaluation. 

CTS-02L This contingency measure would further regulate the emissions from motor 

vehicle assembly line operations, of which there is currently only one in the Basin. The 

expected emission reductions of 40 pounds per day of VOC. The administrative costs of 

rule development do not justify pursuing the measure at this time.

PRC-02 This measure’s aim of achieving further emission reductions from bakery 

operations would require the application of controls on low-emitting bakeries. Larger 

emitting bakeries are currently controlled by the terms of existing Rule 1153. The 

remaining bakeries represent a small source category and the expected emission 

reductions would be minimal (approximately 160 pounds per day of VOC). At this time 

it is more cost effective to proceed with the implementation of other measures which can 

achieve a greater emission reduction at equal or lesser administrative cost.
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PRC-05 The malt beverage, wine and brandy producing facilities within the District’s 

jurisdiction represent a minimal emissions source category. The anticipated emission 

reductions from this control measure would be less than 20 pounds per day. The 

administrative burden of proceeding with implementation of this measure is not at this 

time justified by the minimal emission reductions that would be gained.

MON-02This control measure seeks emission reductions due to excessive starts of new 

and used vehicles at car dealerships. The measure would be implemented either through 

District regulations or local ordinances. There were no emission reduction estimates for 

this measure in the 1994 AQMP. Enforcement issues do not justify pursuing this 

measure at this time.

MON-04This control measure seeks emission reductions due to excessive curb idling. 

The measure would be implemented through local ordinances. There were no emission 

reduction estimates for this measure in the 1994 AQMP. Enforcement issues do not 

justify pursuing this measure at this time.

CTY-07 This contingency measure seeks further emission reductions through limiting 

goods movement activity if the Basin does not attain an applicable federal air quality 

standard. Several concerns are raised with such a program including economic impacts 

to the region and the appropriate implementation authority. As such, further evaluation 

to the feasibility and cost-effectiveness of this measure is needed.

DELETED MEASURES

Table 9-3 lists the measures contained in the 1994 AQMP which are recommended for 

deletion. These measures have been determined to be infeasible, based on cost, 

technical, social acceptability, legal authority, and administrative factors.
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TABLE 9-3

Measures Removed*

AQMP Measure 

Number

Title Pollutant Principal 

Reason**

CMB-05 Clean Stationary Fuels NOx, SOx, 

PM10

2, 3

CTS-01 VOC RECLAIM VOC 4

CTS-02F Further Emissions Reductions from Motor 

Vehicle and Mobile Equipment NonAssembly Line Coating Operations (Rule 

1151)

VOC 1

CTS-02I(2) Further Emission Reductions from Graphic 

Arts Operations (Rule 1130)

VOC 1

ISR-01 Special Event Centers VOC, NOx, 

SOx

4

ISR-02 Shopping Centers CO, PM10 4

ISR-03 Registration and Commercial Vehicles CO, PM10 4

ISR-04 Airport Ground Access CO, PM10 4

ISR-05 Trip Reduction for Schools CO, PM10 4

PRC-04 Emission Reductions from Rubber Products 

Manufacturing 

VOC, PM10 3

* These measures and the reasons for their removal from the Plan are further discussed in the 

Environmental Impact Report for the AQMP.

** 1= Not cost-effective (H&SC 40922(a))

 Not economically feasible (PRC21061.1)

2 = Technically infeasible (H&SC 40922(b))

 Not technically feasible (PRC21061.1)

3 = Minimal emission reduction potential (H&SC 40922(b))

 Not feasible due to social impact considerations and cost of administrative burden. (PRC21061.1) 

4 = Low public acceptability (H&SC 40922(b)

 Not feasible due to social impact considerations (PRC21061.1)

5 = Limited authority per SB 772 (Hurtt) and SB 437 (Lewis)
Chapter 9 Contingency Measures

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TABLE 9-3

(Concluded)

AQMP Measure 

Number

Title Pollutant Principal 

Reason**

RFL-01 Emission Reductions from Utility Equipment 

Refueling Operations

VOC 3

RFL-03 Emission Reductions from Pleasure Boat 

Fueling Operations

VOC 2

FSS-01 Stage I Episode Plans All Pollutants 5

CTY-06 Parking Cash-Out for Employers Having 25 

or more Employees

All Pollutants 5

* These measures and the reasons for their removal from the Plan are further discussed in the 

Environmental Impact Report for the AQMP.

** 1= Not cost-effective (H&SC 40922(a))

 Not economically feasible (PRC21061.1)

2 = Technically infeasible (H&SC 40922(b))

 Not technically feasible (PRC21061.1)

3 = Minimal emission reduction potential (H&SC 40922(b))

 Not feasible due to social impact considerations and cost of administrative burden. (PRC21061.1) 

4 = Low public acceptability (H&SC 40922(b)

 Not feasible due to social impact considerations (PRC21061.1)

5 = Limited authority per SB 772 (Hurtt) and SB 437 (Lewis)

The rationale for deleting these 1994 AQMP control measures from the 1997 AQMP is 

explained in the following paragraphs.

CMB-05 This control measure was intended to achieve emission reductions by requiring 

the use of clean fuels in stationary sources. The NOx emission reductions which were 

expected from this control measure will be achieved through the implementation of 

existing NOx control rules. Additionally, due to issues of safety and operating 

requirements, it is not feasible in all circumstances to completely eliminate the option for 

stationary sources to use standard fuels as a back up fuel during emergencies or other 

unexpected situations. 

CTS-01 The proposal to implement a RECLAIM program for VOC emissions has been 

placed on hold at this date. In place of CTS-01, substitution control measures from the 

1994 AQMP are proposed to be implemented in the 1997 AQMP. This measure is not 

considered socially feasible at this time.
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CTS-02F This control measure calls for further control of sources currently regulated 

under Rule 1151 sources. The measure would affect a large number of very small 

operations. The costs of implementing the measure, estimated at $50,600 per ton, are 

high and the emission reduction potential is minimal in comparison to the number of 

sources involved. The measure is, therefore, not considered to be feasible due to its high 

impact on small operations and the costs of implementation.

CTS-02I(2) The further control of emissions from graphic arts operations was found not 

to be cost effective. The estimated cost per ton would exceed $100,000. Given the 

existing control on graphic arts operations and the control cost this additional measure 

would place on these operations compared to the amount of emission reductions that 

would be achieved, the measure has been dropped.

ISR-01 through ISR-05 These control measures would have required actions by indirect 

sources to reduce emissions resulting from vehicle trips. These indirect sources do not 

have any control over the actions of motorists driving to their facility, unlike employers. 

Moreover, except in the case of schools, there is not a continuing, repetitive pattern of 

trips to these sources. For these reasons, it is much more difficult for these sources to 

reduce trips through ridesharing programs than it is for larger employers. Over the last 

few years, the legislature has consistently restricted, and bills have been introduced, to 

abolish district authority over indirect sources. This contributes to the conclusion that 

these measures are infeasible due to social considerations. In addition, 1996 state 

legislation eliminated the specific transportation performance standards which motivated 

the inclusion of these measures in previous plans.

PRC-04 The emission reduction potential from control of rubber products manufacturing 

envisioned in this measure is below 20 pounds per day. The minimal emission reduction 

potential of this measure is outweighed by the costs and administrative burden of 

adopting the measure.

RFL-01 This control measure would require the design and use of a fuel tank interface 

for utility equipment to accept only an interlocking fuel spout. In addition, gasoline 

dispensing facilities would be required to only dispense gasoline into approved non-spill 

containers. Further evaluation of this measure indicates that at this time, this measure is 

not cost-effective and is administratively burdensome relative to the potential emission 

reductions. Enforcement of this control measure would require monitoring thousands of 

consumers that fill small fuel containers and then transfer that fuel into utility equipment, 

such as lawn and garden equipment. The cost and time required for the District or ARB 

to certify or approve fuel tanks or nozzles is not an effective use of resources at either 

agency or the industry, given the modest potential emission reduction of 80 pounds per 

day. Thus, the administrative burden and cost to enforce this control measure would be 

extensive relative to the minimal emission reduction potential of this measure.
Chapter 9 Contingency Measures

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RFL-03 Upon further analysis, implementation of this measure has been determined to 

be technically infeasible and not cost-effective. Through various meetings, the U.S. 

Coast Guard has raised issues regarding regulating pleasure boat refueling operations and 

has expressed concern for public safety. In addition, it has become apparent that most 

pleasure boat fueling operations occur at conventional gasoline dispensing facilities as 

compared to marinas, which typically have only one fueling facility.

FSS-01 This further study measure was proposed to develop programs to reduce 

emissions under Stage I episode conditions. State law has removed the District’s 

authority to require rideshare programs. As such, this measure has been removed from 

the 1997 AQMP.

CTY-06 This contingency measure was proposed to reduce emissions through 

implementation of parking cash-out programs for employers having 25 or more 

employees. State law has removed the District’s authority to require rideshare programs. 

As such, this measure has been removed from the 1997 AQMP.