Matthew Rodriquez Secretary for Environmental Protection

June 19, 2014 

# Air Resources Board Mary D. Nichols, Chairman

1001 I Street· P

.O

. Box 2815 Sacramento, California 95812 • www.arb

.ca .gov

Deborah Jordan , Director Air Division, Region 9 U.S. Environmental Protection Agency 75 Hawthorne Street San Francisco, California 94105 Dear Ms

. Jordan: Edmund G. Brown Jr. Governor

On November 21, 2013, the Air Resources Board (ARB or Board) approved revisions to California's State Implementation Plan (SIP) for the both the San Joaquin Valley Air Basin and the Sacramento Federal Ozone Nonattainment Area. ARB formally submitted these SIP revisions to the U. S. Environmental Protection Agency (U

.S. EPA) on December 20 , 2013 and December 31, 2013, respectively

. Appendix D ofthe San Joaquin Air Basin Plan and Appendix F-1 of the Sacramento Plan both demonstrate compliance with the Vehicle Miles Traveled (VMT) Offset Requirement of the Clean Air Act for the 8-hour ozone and 1-hour ozone standards in the San Joaquin Valley Air basin, and for the 8-hour ozone standard in the Sacramento Federal Ozone Nonattainment area. (Clean Air Act Section 182(d)(1)(A))

. As requested by U.S. EPA staff to aid its review of these SIP revisions, ARB is providing further information and analysis which support these demonstrations of compliance with the VMT Offset Requirement. As was done in Appendices D and F-1 of the respective plans, these additional analyses use California's approved motor vehicle emissions model, EMFAC 2011. EMFAC calculates emissions from vehicles when they are running using trip-based VMT calculated by metropolitan planning organizations (MPO) combined with vehicle population data and corresponding emission rates. In addition to running emissions, these additional analyses also include emissions from other processes associated with vehicle use: starts, hot soaks and running loss emissions. How emissions are calculated for these processes as well as running exhaust are shown on the attached EMFAC flow chart. The two remaining processes in the chart, diurnal and resting emissions only occur when a vehicle is not being used and therefore are not included in this additional analysis

. The emission rate information embedded in EMFAC and used in this analysis reflects the aggregate impacts of all California's mobile source control program . A list ofthe

The energ y c hallenge faci ng California is real. Every Calif ornian needs to take immedi ate action to reduce energ y consumption

. Fora list ofsimpl e ways you can reduce demand and cutyourenergycosts, see our website: http://www.arb

.ca .gov. California E nvironmental Protection Agency Printed on Recyc ledPaperMs. Deborah Jordan, Director June 19 , 2014 Page 2
mobile source control measures adopted since 1990 were included in the SIP revisions as attachments to their respective appendices. This list is comprehensive and not all the measures are of equal impact. Of the measures on that list, those most critical to achieving the VOC reductions contributing to compliance with the VMT Offset Requirement are the Low Emission Vehicle Program, the Low Emission Vehicle Program II , the Advanced Clean Cars Program , reformulated gasoline , and Smog Check improvements

. To simplify U

.S

. EPA's review, we have provided the new information in the same format used for the appendices. Also enclosed at the request of U

.S. EPA staff are output files from EMFAC 2011 for all scenarios used in each of the VMT Offset analyses

. (Provided on the enclosed COs) If you have any questions , please contact me at (916) 322-2739 , or have your staff call M r. Jon Taylor, Chief, Transportation Planning Branch at (916) 322-0285
. Sincerely, Lynn Terry Deputy Executive Officer Attachments Enclosure (compact disks (2))
cc: See next page.Ms. Deborah Jordan, Director June 19, 2014 Page 3

cc: (with attachments and enclosure) Mr. Seyed Sadredin Executive Director/Air Pollution Control Officer San Joaquin Valley Air Pollution Control District 1990 East Gettysburg Avenue Fresno, California 93726 Mr

. Samir Sheikh Director of Strategies and Incentives San Joaquin Valley Air Pollution Control District 1990 East Gettysburg Avenue Fresno, California 93726 Ms. Tanisha Taylor San Joaquin Council of Governments 555 East Weber Avenue Stockton, California 95202 Mr. Larry Green Air Pollution Control Officer Sacramento Metropolitan Air Quality Management District 777 121 h Street, Third Floor Sacramento, California 95814 Mr. Dave Johnson Air Pollution Control Officer El Dorado County Air Quality

Management District 330 Fairlane Court Placerville, California 95667 Mr. Tom Christofk Air Pollution Control Officer Placer County Air Pollution Control District 11 0 Maple Street Auburn, California 95603 Continued next page.Ms

. Deborah Jordan, Director June 19, 2014 Page4

cc: (continued) Mr

. Christopher D. Brown Air Pollution Control Officer Feather River Air Quality Management District 1007 Live Oak Blvd , Suite B-3 Yuba City, California 95991 Mr

. Mat Ehrhardt, P

. E. Air Pollution Control Officer Yolo-Solano Air Quality Management District 1947 Galileo Court, Suite 103 Davis , California 95618 Mr. Mike McKeever Executive Director Sacramento Area Council of Governments 1415 L Street, Suite 300 Sacramento , California 95814 Mr

. Steve Heminger Executive Director Metropolitan Transportation Commission 101 Eighth Street Oakland , California 94607-5769 (without attachments or enclosure) Mr. Jon Taylor, Chief Transportation Planning Branch Air Quality Planning and Science DivisionMs

. Deborah Jordan, Director June 19, 2014 Page 5
bee: (w/out attachments or enclosure) Kurt Karperos, AQPS Karen Magliano, AQPS Sylvia Vanderspek, AQPS Nesamani Kalandiyur, AQPS Dennis Wade , AQPS EO Chron (2 copies) AQPSD Chron SIP Library Assignment #9176/#18567 X :\VMT Offset Demonstration\DRAFT Sac SJV Transmittal letter VMT Offset US EPA.doc X:\VMT Offset Demonstration\SJV VMT Offset Doc for EPA March 2014 Reformated.docx X:\VMT Offset Demonstration\DRAFT Sac VMT Offset Doc for EPA Reformated

.docx X:\VMT Offset Demonstration\VMT

_offset_EMFAC Flow Chart

.docx