2007 Ozone Plan 

Chapter 4 

 

Strategy 
2007 Ozone Plan 

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San Joaquin Valley Unified Air Pollution Control District April 30, 2007

Chapter 4: Strategy 

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Chapter 4: Strategy

4.1 INTRODUCTION 

This chapter discusses the District’s overall strategy for achieving emissions reductions 

and bringing the San Joaquin Valley into attainment of the federal 8-hour ozone 

standard. The District’s overall approach relies on achieving the maximum reductions in 

the most expeditious manner possible. The approach relies on sound science and the 

best available technology. Given the magnitude of reductions needed to reach 

attainment and the associated challenges associated with such an effort, the District is 

implementing a four-faceted control strategy, described below. 

4.2 OVERALL APPROACH 

The District’s overall approach is concentrated on feasible measures that will get the 

most reductions. Each measure the District undertakes demands a significant 

allocation of staff time and opportunities for public participation, review, and comment. 

To improve the air as quickly as possible, control measures that are expected to yield 

the greatest health benefit will be undertaken first. 

The District must also approach control measures with sound science and the best 

available technologies. Achieving emissions reductions requires investment from local 

businesses and citizens. To ensure that investments will yield the desired returns, the 

District will support control development efforts with the scientific studies needed to 

substantiate the investments and efforts. In all cases, the District will rely on the latest 

advanced technology. 

4.2.1 Integration of Ozone and PM2.5 Strategies 

Since the San Joaquin Valley is also designated nonattainment for the federal PM2.5 

standards, control strategies for PM2.5 and 8-hour ozone will be integrated and 

harmonized to the extent possible. The PM2.5 plan is due to EPA in April 2008, and the 

attainment year is 2010, though EPA can grant extensions until 2015. Secondary PM2.5 

can form in the atmosphere from other compounds (see Figure 4-1), such as NOx, or 

PM2.5 can also be emitted directly into the atmosphere. Since NOx is a precursor to 

both ozone and PM2.5, the District’s strategy emphasizes NOx controls. As ARB’s 

PM2.5 modeling progresses, understanding of PM2.5 precursors and formation in the 

Valley will be improved, allowing further opportunities for strategy refinement and 

harmonization. 
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Figure 4-1 PM2.5 Formation 

4.3 FOUR-FACETED CONTROL STRATEGY 

Meeting the challenge of attaining the 8-hour ozone standard in the San Joaquin Valley, 

with its meteorological and topographical disadvantages as well as its growth rate and 

automobile-dependent land use patterns, will require an innovative approach that 

involves every person and business in the Valley. The centerpiece of the District’s 2007 

Ozone Plan is the control strategy, the measures that the District and others will put in 

place to control ozone precursor emissions in an effort to decrease concentrations of 

ozone, so that the San Joaquin Valley can attain the federal standards. ARB modeling 

suggests that NOx emissions in the Valley will need to be reduced by 75% of their 2005 

levels. 

To achieve this, the District is considering a four-faceted control strategy: 

! Regulatory Control Measures for Stationary Sources - The regulatory 

component will consist of traditional “command-and-control” regulations, like 

most current rules in the District’s Rulebook section titled, “Regulation IV – 

Prohibitions.” 

! Incentive-based Strategies - Incentive-based strategies will build on the 

District’s current grant programs, which use a combination of state and local 

PM2.5 Formation Formation

Organic 

compounds

Organic 

compounds

Volatile compounds Volatile compounds

Semivolatile

compounds

Semivolatile

compounds

Semivolatile and 

gaseous compounds

Semivolatile and 

gaseous compounds

Organic Particles Organic Particles

Secondary Organic 

Particles

Secondary Organic 

Particles

NO NO2

Ozone

NH3

SO2 Inorganic 

Sulfate

Inorganic 

Sulfate

Ammonium 

Sulfates

Ammonium 

Sulfates

Ammonium 

Nitrate

Ammonium 

Nitrate

Chemical Deposition

RO2

Chemical Deposition

H2SO4

Inorganic 

Nitrates

Inorganic 

Nitrates

NO3

N2O5

HNO3

#

O2 H2O2 O3

OH H2O

OH

O2

OH

O2
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funds. These programs have expanded in funding and increased in 

sophistication over the years. 

! Innovative Strategies and Programs – This part of the overall control strategy 

promotes innovative programs that are not traditional regulatory or incentive 

based strategies. Such innovative strategies achieve reduction of emissions 

from source categories not traditionally regulated by the District through 

alternative routes. Such programs to be pursued in the upcoming years include: 

Employer-Based Trip Reduction, Alternative Energy Production, Energy 

Conservation, Heat Island Mitigation, Indirect Source Review Enhancement, 

Green Contracting, Expanded Spare-The-Air, Episodic and Regionally-focused 

Control Measures, and Advanced Emissions Reductions Options (AERO). 

These innovative strategies and programs are discussed further in Chapter 8. 

! Local, State, and Federal Sources/Partnerships - This component of the 

Valley’s control strategy acknowledges that local, State, and Federal agencies 

must each reduce emissions from the sources under their jurisdiction to reach 

the 75% NOx reductions needed. 

Each facet of the four-part control strategy will consist of a number of emission control 

measures, each of which will address specific source categories. 

The development of the District’s components of this strategy is based on twelve 

guiding principles:

Guiding Principles 

1. With public health as our number one priority, meet the federal ambient 

air quality standards as expeditiously as is practicable. 

2. Recognize that the Valley’s economic vitality and prosperity are 

essential to having the resources necessary to achieve our public 

health goals. 

3. Recognize that no “silver bullet” exists – every sector, from the public 

through all levels of government, business, and industry, must reduce 

emissions. 

4. Achieve emission reductions in the most cost-effective way possible to 

get the “biggest bang for the buck.” 

5. When scheduling regulatory actions such as rules and strategies, allow 

adequate time for full public participation. 

6. Consider total impact on businesses; allow reasonable time for 

implementation of current and future rules. 

7. Give precedence to nitrogen oxides (NOx) emissions reductions to 

assist with attainment of the federal standard for particulate matter 

(PM). NOx emissions contribute to both ozone and PM formation. 

8. Take advantage of imminent new technologies and allow more time to 

get more reductions if needed. 

9. Do not let “one-size-fits-all” governmental policies and bureaucracy 

stand in the way of timely, innovative, and cost-effective emission 

reductions. 
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10. Use sound science in assessing public health impacts, the magnitude 

of emissions from various source categories, and the availability, 

effectiveness, and feasibility of emissions control measures. 11. Do not rely exclusively on the state and federal government to reduce 

mobile source emissions. Consistent with state and federal laws, find 

effective and innovative regulatory and incentive measures at the local 

level to address mobile source emissions.

12. Consider seasonal, episodic, and regional measures to more 

strategically target limited resources for optimum air quality benefits 

throughout the Valley.

4.4 STATE AND FEDERAL COMPONENTS 

As discussed in Chapter 3, the District has jurisdiction over only 55% of the total VOC 

emissions inventory and just 20% of the NOx emissions inventory. The remaining 

portions of the inventory, which include mobile sources, pesticides and fertilizers, and 

consumer products, are under the jurisdiction of the state and federal governments. 

4.5 SUPPORT FROM OTHER DISTRICT PROGRAMS 

The success of District’s control strategy depends in part on the District’s compliance 

program. Programs like the District’s environmental review, public information, 

education, and outreach also contribute to the District’s successes in improving air 

quality. 

4.5.1 Compliance/Enforcement 

The District operates a highly efficient and effective compliance program. The 

Compliance Division’s staff of 75 personnel maintains a strong presence in each of the 

District’s three regional service areas. The Compliance Division has a critical role in 

ensuring that rules and regulations relied upon to attain the NAAQS are fully enforced. 

The District uses several methods to increase compliance while maintaining a 

streamlined process. The first method to ensure compliance is education and outreach. 

Educational approaches include an extensive array of compliance assistance bulletins 

and a compliance school for those who have received a notice of violation. A second 

method is the increased use of information technology. The District’s website, along 

with printed information, helps to ensure that the regulated community has full access to 

applicable regulations and instructions. The District is automating its permitting system 

to enable applicants to take advantage of streamlined applications for permits such as 

those required for agricultural burns. By making the process easier, compliance rates 

will be higher. The third method is the traditional field enforcement activities that include 

rigorous source tests, inspections, and response to complaints. The District has toll free 
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complaint hot lines that enable the public to contact an on-call inspector at any time. 

The final approach falls into the District’s legal and Mutual Settlement area. District 

legal staff has the authority to issue large penalties as one of the strongest compliance 

incentives. 

“Compliance School” is offered as a voluntary educational training session to individuals 

and companies who have received a “Notice of Violation Settlement Letter” from the 

District. A person having the authority and responsibility to control the event that led to 

the violation of a District rule may qualify for a one-time penalty reduction by attending 

this two-hour education session. The first hour presents an overview of the air quality 

problems within the SJVAB. The second hour discusses rule requirements and 

provides recommendations regarding rule compliance.

The Compliance department supports its efforts with the following Compliance 

Assistance Bulletins, which are available on the District’s website: 

! Continuous Emission Monitoring (CEM) Reporting Requirements 

! Dealing with Excessive Liquid in Vapor Return Hoses Equipped with Liquid 

Removal Devices 

! Equipment Tuning Procedures for Boilers, Steam Generators and Process 

Heaters 

! Portable Equipment Recordkeeping 

! Rescue Requirements for Floating Roof Tank Inspections 

! Rule 4692 – Chain-driven Charbroiling Equipment 

! Source Testing Requirements for Alternative Monitoring Schemes for Boilers, 

Steam Generators, and Process Heaters 

! Title V Reporting Requirements 

! Vineyard Removal Update 

! Vegetable Crop Residue Burning 

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

! Rule 4702 – Spark-Ignited Internal Combustion Engines 

! Regulation VIII – Fugitive Dust Control at Construction Sites 

! Rule 4604 – Wood Products Coating Operations 

! Source Test Scheduling 

! Restrictions of Agricultural Burning – June 1, 2005 

! Criteria Source Test Contractors Reminder to Renew Certification 

Other informational documents or web pages include the following: 

! Fugitive Dust Control at Agricultural Sources 

! Asbestos Requirements for Demolitions and Renovations 

! Abrasive Blasting Operations 

! Degreasing Operations 

! Industry Self Inspection Program 
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4.5.2 Public Education, Awareness, and Information 

Engaging the public in efforts to reduce emissions is a key element of the ozone 

attainment strategy. Education increases public support for new and controversial 

regulations. Helping people understand the complex issues underlying the ozone 

problem further improves this support. Individuals can undertake many actions to 

reduce ozone precursor emissions. When members of the public are aware that they 

can make a difference and are convinced that the problem is real, many people will 

change their behavior in a positive way. 

The District's education and information program has expanded and evolved over the 

years. It uses a variety of media, strategies and techniques to ensure the widest 

possible dissemination of air-quality information. It includes direct-marketing 

approaches with traditional media, including television, radio and print as well as new 

technologies, such as the District’s website and listserv emails, and non-traditional 

methods such as word-of-mouth marketing. The District networks with other agencies, 

educational institutions, community organizations, industry groups and the news media 

in educational efforts. It produces educational materials such as videos, brochures, and 

fact sheets that provide focused information to targeted audiences. 

4.5.2.1 Programs 

Agriculture Outreach 

The District has a strong agriculture outreach component, reflecting the importance of 

this economic sector to the Valley air basin’s economy and to the ozone-attainment 

strategy. The District works closely with the Valley’s agricultural industry leaders, 

leading to perhaps the most intensive research into agriculture-related emissions and 

conservation practices anywhere in the country. 

Agriculture Improving Resources (A.I.R.) is a partnership formed to aid agriculture in 

promoting voluntary improvement of air quality through scientifically proven, costeffective measures. Partners in A.I.R. include the District, the California Air Resources 

Board, California Cotton Ginners and Growers Associations, Nisei Farmers League, 

California Citrus Mutual, California Grape and Tree Fruit League, Raisin Bargaining 

Association, California Apple Commission, California Plant Health Association, Kern 

County Farm Bureau, Kings County Farm Bureau, Fresno County Farm Bureau, Tulare 

County Farm Bureau, Madera County Farm Bureau, Merced County Farm Bureau, 

Stanislaus County Farm Bureau and the USDA Natural Resources Conservation 

Service. This partnership will play an increasingly important role in providing 

information to growers on a wide variety of air-quality programs. 

The Dairy Permitting Advisory Group (DPAG) outreach effort was undertaken to 

address regulation of dairy emissions in compliance with a 2003 state law. Dairy 

industry stakeholders were concerned by the lack of scientific foundation for 

establishing emissions estimates and determining Best Available Control Technologies 
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(BACT). Settlement for these concerns established a special commission to evaluate 

available scientific studies and advise the Air Pollution Control Officer on permitting and 

BACT determinations. DPAG membership included agency technical staff, scientists, 

stakeholder experts, and concerned citizens. All proceedings were conducted in public 

meetings with conference-call access. Scientists conducting new research, requested 

by the agencies to provide a sound basis for emissions-factor evaluation, appeared at 

proceedings and participated by phone and written communication in response to 

questions from the DPAG and public meeting participants. Results of this process were 

presented to the Air Pollution Control Officer (APCO) and reported to the District 

Governing Board. In addition to advising the APCO, the results of these proceedings 

defined additional research projects to fill remaining information gaps and refine 

emission measurements provided by the initial studies. 

Following review of the DPAG proceedings, the District developed Rule 4570 to address 

emissions from large confined animal facility operations (CAFO) and adopted the rule 

after holding public workshops and rule adoption hearings. Extensive public outreach 

has begun for the implementation of this rule. The District will be working with 

stakeholders to develop an outreach program for compliance assistance. The District 

works closely with farm bureaus in all eight counties to inform and update agriculture 

industry members on District activities and policy development. Extensive outreach to 

the agricultural community was also conducted on the CMP and Major Source (Title V) 

permitting programs. 

Spare the Air 

Spare the Air is a voluntary effort from June through September aimed at reducing air 

pollution, specifically ozone. Typically, there are 15-25 Spare the Air days per season, 

varying by location within the Valley. Spare the Air works by notifying Valley residents 

via television, radio, newspaper, and participating worksites of the days when air quality 

is forecast to reach unhealthy levels. When a Spare the Air day is called, the District 

encourages residents to reduce or avoid activities that cause air pollution for the day. 

Residents are asked to postpone or avoid such activities as using oil-based paints, 

solvents, aerosol spray cans, and 

gasoline-powered lawn equipment, 

and avoid making unnecessary 

vehicle trips. Spare the Air outreach 

is conducted in English, Spanish, and 

Hmong, and campaign materials 

include outdoor (billboard), TV and 

radio spots, in addition to live 

“readers” on radio news shows and 

“crawls” on TV stations. 
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Clean Green Yard Machines 

The Clean Green Yard Machines program, the District’s 

annual lawnmower trade-in program, is one of the most 

popular programs administered by the District. This 

year, the program was expanded to include nearly twice 

as many locations and machines available for trade-in. 

This is a valuable component of the District’s 

overarching ozone-reduction strategy, as gas-powered 

lawnmowers are a significant contributor to precursor 

emissions. The program represents a significant 

commitment of District resources, including advertising, 

planning and execution. The Clean Green Yard Machines program commands an 

extremely high level of media visibility, including positive editorial coverage by every 

daily newspaper in the District’s eight counties. 

Check Before You Burn 

The District’s Check Before You Burn Program is an 

educational program that supports the wood burning 

curtailment component of Rule 4901. As in Spare the Air, 

public-outreach information is regularly conveyed through 

cooperation with broadcast and print editorial media in all 

three regions. 

 

Air Quality Index Forecasts 

The daily forecast for the Air Quality Index (AQI) (formerly 

known as the PSI – Pollutant Standards Index) is faxed 

and emailed directly to local television and radio stations, 

newspaper publications, as well as schools, health 

organizations, and others who have signed up to receive 

the notices. The forecast AQI helps educate the public about air pollution and advise 

residents when air quality is expected to be unhealthy, so they can modify their activities 

and protect their health. Although the number of unhealthy-air days over the course of 

the summer is affected by many factors, the exceedingly low number of such days 

during 2004-05 was in part attributed to a high level of public awareness and 

commensurate voluntary participation in ozone-mitigating behaviors, as a result of 
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pervasive publicity surrounding daily air-quality forecasts. The District’s staff 

meteorologists provide highly accurate air-quality predictions for the air basin. 

Forecasts now use more detailed information specific to the local daily conditions. 

Youth Education 

As part of the youth education program, the District’s Public Information staff makes 

frequent and regular presentations to schools within the District’s eight counties, ranging 

from pre-school through college, and at any time, day or night. Public Information staff is 

contacted frequently by school district officials to offer input on questions of student 

health during ozone episodes and alternative activity suggestions. 

Furthermore, the District offers elementary, middle, and high school air-quality 

curriculum materials to all teachers in the San Joaquin Valley. The elementary school 

curriculum is accompanied by class material and incentive items, and focuses on 

general air-quality issues. The middle and high school curriculum focuses on mobile 

source emissions and is a science-based laboratory series. Public Information staff has 

also participated on a mentor basis for in-depth, long-term high-school science projects 

on ozone in specialized programs such as the Center for Advanced Research and 

Technology (CART), in the Fresno Unified and Clovis Unified school districts. 

The District has also partnered with local organizations to distribute Air Quality Flag 

program materials to all schools in the Valley over the next few years. The multicolored flags are flown each day to indicate the forecast air quality. The program has 

accompanying materials that provide indoor activities for students on days when air 

quality is expected to be poor. Furthermore, the materials outline behavior 

modifications children and adults can take to help improve air quality. 

Bilingual Outreach 

The ability of the District to provide real-time translation services for a significant portion 

of the Valley’s population is a priority of utmost importance. Therefore, in 2006, the 

District’s Public Information section hired a full-time staff member for Spanish-language 

outreach and translation activities. The District now has live translation capabilities, a 

service that has been used at board meetings, public meetings, the July 2006 Town Hall 

meetings, and other events. Additionally, the District provides Hmong-language 

information and outreach materials for the two major outreach programs: Spare the Air 

and Check Before You Burn. 

Media Relations 

The District maintains an effective and efficient media relations program, providing 

timely information to reporters and helping ensure news coverage accurately reflects 

the Air District’s position, actions, and rules. Staff members handle about 1,000 media 

inquiries annually from local, regional, national, and international news organizations. 

The District also provides a dedicated phone number for reporters who need information 

during non-work hours. District staff work to cultivate open communication with 

environment beat reporters to help them understand the air basin’s complex air-quality 
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issues and encourage them to contact the Air District any time an air-quality story 

warrants District comment. 

Public Awareness Study 

In 2005, an extensive, broad-based marketing study was commissioned by the District 

to reveal and quantify the public’s level of air-quality knowledge, behavior adaptation to 

current air-quality information and general understanding of the District’s mission and 

activities. The study reported an exceptionally high level of understanding of ozone 

issues, which the research group attributed to successful public outreach by the District. 

4.5.2.2 Events 

Air-Quality Conferences 

The District organizes and executes an extensive air-quality conference every other 

year. A wide variety of organizations, businesses, and individuals participate. More 

than 200 representatives of business and industry, along with civic leaders, air-quality 

experts, health officials, and community activists, came together to discuss the Valley’s 

air challenges at the District’s 2004 Air Quality Symposium, September 29-30, in 

Bakersfield. “Unique Valley, Unique Solutions: Working Together for Clean Air in the 

San Joaquin Valley” featured panel discussions exploring innovative solutions for 

cleaning the Valley’s air. The event also included keynote speakers, general sessions, 

breakout sessions on special-interest topics, and air-quality exhibits. 

Outreach to inform the public on air quality research for ozone and particulates was 

expanded in 2006 through a free public symposium. “Central California Air Quality 

Research, How Science is Charting a Path to Cleaner Air” was co-sponsored by the 

District, ARB, and participants in the Central California air quality studies. The one-day 

conference provided information to the public developed by more than $60 million of 

research on ozone and particulates. Keynote speakers provided policy-relevant and 

technical findings of both the CCOS and the California Regional Particulate Air Quality 

Study (CRPAQS). Public questions were encouraged after each presentation, 

facilitated as needed by Spanish translation provided by District staff. Public interest in 

the symposium exceeded expectations and fully booked the capacity of the conference 

center. 

Town Hall Meetings 

During July 2006, the District held a series of six town-hall meetings in six cities 

throughout the District over the course of three days. The purpose of these meetings 

was to educate and inform stakeholders and the general public about both short-term 

and long-term air-quality goals and challenges, including attainment of the eight-hour 

ozone standard. A primary objective was to obtain maximum public input for innovative 

strategies with which to meet this goal. 

These meetings were held in each region of the District and included rural locations, in 

order to include populations unlikely to attend regular meetings in urban settings. The 
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District sent its highest-ranking officials and managers to make presentations and 

respond to public questions and comments: the APCO, Deputy APCO, Director of 

Planning and other key staff, as well as representation by Public Information 

administration. Additionally, live Spanish translation was provided. Public turnout was 

exceptional. 

Other Events 

The District works with local groups such as the American Lung Association and 

rideshare agencies to promote annual events that reinforce clean-air activities. Some of 

the annual local and national events in which the District participates include: 

! Earth Day – local organizations sponsor various events, in April; 

! Clean Air Month – American Lung Association sponsors various events, in May; 

! Air Quality Awareness Week – sponsored by the U.S. Environmental Protection 

Agency, in May; 

! Rideshare Week – sponsored by local rideshare committees, in October; 

! Car Care Month – sponsored by the American Lung Association and Calif. State 

Automobile Association, in October. 

! Bike To Work Week – sponsored by the Fresno County Bicycle Coalition, in May. 

Many local activities are conducted by organizations and agencies throughout the 

Valley, including the annual Clean Air Business Expo, sponsored by Valley Clean Air 

Now; the World Ag Expo in Tulare; and the annual Conservation Fair by the County of 

San Joaquin. The District participates in these events and many others, and 

encourages activities that increase public awareness of air pollution and public 

participation in programs or activities to reduce air pollution. Many of the District 

activities can be found on its web site at www.valleyair.org.

4.5.2.3 Materials 

Informational Brochures 

The District continues to develop new and updated brochures to address air-quality 

issues in the air basin. Existing brochures and those under development include: 

! There is Money in the Air: information about emission-reduction incentive 

programs and how to apply 

! Spare the Air 

! Become a Spare the Air Employer Partner 

! Complaint Procedures 

! Understanding Air Toxics and Risk 

! Aqueous Cleaning Solutions Used in Degreasing Operations 

! Lets’ Clear the Air!: discusses emissions from motor vehicles and provides 

practical tips on how to reduce those emissions, keep a car well tuned, and 

report smoking vehicles 

! Fact Sheet: in bullet points, discusses air-quality improvements and challenges, 

and details District program activities 
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! Check Before You Burn: provides information on the District wood-burning rule 

and how to comply 

! Fugitive Dust Control 

! Air Quality Natural Events Action Plan Episodes 

! Air Quality Flag Program 

! Leading the Way to a Clearer Future: provides general information about air 

quality, the Air District and how members of the public can help clear the air 

! Indirect Source Review: summarizes a rule designed to reduce emissions from 

new development in the SJVAB and informs developers how to comply 

! Clean-Air Yard Care: provides pollution-reducing tips for lawn and garden care 

Educational Videos 

A wide variety of educational videos are used to promote behavior change and to 

educate the public on air-quality issues. For example, a Spare the Air video outlines 10 

steps the public can take to reduce their contributions to summer time pollution. 

Newsletter 

Valley Air News is a monthly publication of the District and is widely distributed 

throughout the air basin. The newsletter highlights current activities of the District, 

summarizes Governing Board actions, commends efforts by Valley businesses to 

reduce air pollution beyond what is required, and discusses other relevant air quality 

issues. 

Point of View 

The annual Spare the Air employer partner newsletter is published each year prior to 

the start of Spare the Air season in June. It provides partners with information on ways 

to implement their programs and lists all participating businesses in the air basin. 

Board Highlights 

The District’s Board Highlights are distributed monthly as a one-sheet publication 

summarizing board activities and actions of that month. 

Public Service Announcements

Public Service Announcements (PSAs) have been created for use on television and 

radio stations throughout the air basin. These 30- to 60-second announcements remind 

the public to use public transportation, share rides to work, walk to lunch, buy 

nonvolatile consumer products, refrain from using their fireplaces on certain unhealthyair days, keep their vehicles properly tuned, use electric-powered lawn equipment, etc. 

4.5.3 Environmental Review 

The District reviews California Environmental Quality Act (CEQA) and development 

proposals received from cities, counties, and other agencies. Whenever development is 

planned or occurs, the District focuses on potential sources of emissions. Among the 
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areas examined are agriculturally productive lands as they convert to non-agricultural 

uses, construction and demolition activities, traffic-generating sources, and potential for 

facilities that may generate hazardous materials. The District developed two documents 

as resources for agencies to use when evaluating potential air quality impacts: the Air 

Quality Guidelines for General Plans (AQGGP) and the Guide for Assessing and 

Mitigating Air Quality Impacts (GAMAQI). The AQGGP is a guidance document and 

resource for cities and counties to use to address air quality in their general plans. 

Section 65302.1 of California Government Code requires cities and counties in the San 

Joaquin Valley to amend appropriate elements of their general plans to include data, 

analysis, comprehensive goals, policies, and feasible implementation strategies (such 

as those in the AQGGP) to improve air quality in their next housing element revisions. 

Cities and counties are required to submit these air quality amendments to the District 

for comment at least 45 days before adoption. 

The GAMAQI is an advisory document that provides lead agencies, consultants, and 

project applicants with uniform procedures for addressing air quality in environmental 

documents. Certain types of development projects are also reviewed under the 

District’s Indirect Source Review (ISR) Program, which reduces emissions of NOx and 

PM10 from new development projects. Other recent development projects have 

mitigated their air pollution impacts through voluntary development contracts with the 

District. 

4.5.4 Sustainable Incentives 

Alternative approaches for reducing emissions, as discussed in the following 

paragraphs, have been suggested for consideration by a number of parties. The District 

is considering how to work these ideas for alternative approaches into its control 

strategy where feasible. 

To promote the implementation of practices that reduce air pollution from a variety of 

sources, including exempt sources, industry suggested the development of sustainable 

incentives. The concept of sustainable incentives includes financial measures, 

programs, and/or prohibitory rule Advanced Emissions Reductions Options plans that 

provide an economic mechanism to fund air pollution reduction measures. Sustainable 

incentives may be in the form of private industry and/or foundation grants, federal 

and/or state government grants, tax credits, prohibitory rule incentives, and other 

programs. 

The concept of sustainable incentives is based upon existing programs such as the 

federal farm bill’s “Environmental Quality Incentives Program (EQIP); the State’s Carl 

Moyer Program; the District’s Heavy-Duty Program (see next section), and other 

programs that offset the implementation cost of pollution reduction measures. Many of 

these existing programs operate within the framework of a partnership involving private 

industry, the public, and public agencies. 
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As proposed by industry, the concept of sustainable incentives revolves around a 

market-based approach to pollution reduction using measures that are economically 

sound and that are supported by scientific research. Basic concepts could include: 

! Local air pollution control/air quality management districts, EPA, and ARB would 

assist local municipalities and other public agencies in acquiring additional 

funding. The funding would be used to implement emission reductions; expand 

existing incentive programs, such as EQIP and Carl Moyer; and offset mitigation 

cost needs of the local transportation agencies and communities. Such funding 

could be generated from either governmental sources in the form of grants or 

from industrial sources in the form of alternative compliance fees or penalties. 

! These regulatory agencies would consider suggestions for alternative emission 

reduction programs that generate equivalent emissions reductions to those 

identified in prohibitory rules, but are less costly to implement. Such programs 

would obtain emission reductions by contributing to other programs like EQIP, by 

reducing onsite emissions, or by allowing the use of valid emissions reductions 

from secondary sources located in the immediate vicinity of those sources 

seeking the use of the alternative emission reductions. Sustainable and other 

District incentives have demonstratively provided a more flexible route for 

emission reductions.