### Appendix C

REVISED Interstate Transport State Im plementation Plan (SIP) for the 1997 8-hour Ozone Standard and PM2.5 to satisfy the Requirements of Clean Air Act section 110(a)(2)(D)(i) for the State of California

(September 21, 2007)(This page intentionally left blank.)September 21, 2007 Appendix C 1 Introduction

Sections 110 (a)(1) and (2) of the Clean Air Ac t require states to submit SIPs that implement, maintain, and enforce a new or revised national ambient air quality standard within three years following prom ulgation of the st andard. Among the SIP elements identified in Section 110(a)(2) is the r equirement to address the transport of pollutants between states. Th is section also requires states to ensure that their SIP does not interfer e with another state’s program to prevent significant deterioration of it s air quality or interfere with vi sibility in another state.

In April 2005, the U.S. EPA notified states of their fa ilure to make the required SIP submission addressing interstate trans port of pollutants related to ozone and PM2.5. This “failure to submit” finding for the required inters tate transport SIPs started a 24-month clock for U.S. EPA to issue a final Federal Implementation Plan (FIP) for any state that does not subm it a plan within that time period.

On August 15, 2006, U.S. EPA issued guidance for submitting interstate transport or “Good Neighbor” SIPs. In accordance with that guidance, this document contains the findings that California meets the requirements of sections 110 (a)(1) and (2) of the Clean Air Act for both the 1997 federal 8-hour ozone standard and the federal PM2.5 standard.

Closest Nonattainment Areas to California

Ozone : The closest 8-hour ozone nona ttainment areas (based on the 1997 standard) are Las Vegas, Nevada, and P hoenix-Mesa, Arizona. However, the status of Clark County, Nevada (Las Vegas), is in flux. The County has requested a “clean data finding” from U.S. EPA based on data from 2004-2006 that shows the area to be in attainment of the 1997 standard. If U.S. EPA makes that finding, Clark County will no longer be considered a nonattainment area.

PM2.5 : The closest PM2.5 nonattainment area is Libby, Montana. Libby is more than 900 miles away from the San Joaquin Valley, the nearest PM2.5 nonattainment area in California.

Evaluation of Significant Contributi on to Nonattainment or Interference with Maintenance of Attainment Standards in Another State

U.S. EPA did an analysis for its Clean Air Inte rstate Rule (CAIR) to identify states that were contributing si gnificantly to nonattainment of PM2.5 and ozone in adjacent states. In the preamble to that rule, U.S. EPA stated that:

“In analyzing significant cont ribution to nonattainment, we determined it was reasonable to exclude the Western U.S., including the States of Washi ngton, Idaho, Oregon, California

, Nevada, Utah and Arizona from fu rther analysis due to geography,September 21, 2007 Appendix C 2 meteorology, and topography. Ba sed on these factors, we concluded that the PM2.5 and 8-hour ozone nonattainment problems are not likely to be affected significantly by pollution transported across these States’ boundaries. Therefore, for the purpose of assessing State’s cont ributions to nonattainment in other States, we have only analy zed the nonattainment counties located in the rest of the U.S.” 1 (emphasis added)

The meteorological discussions below provide more detail.

Ozone : Ozone episodes over the Southwes tern United States are normally associated with strong high pressure systems centered over the Southwest Desert. These meteorological patterns are characterized by clear skies, warm temperatures, and light winds and result in very stagnant conditions over the region. Ozone is not transported over l ong distances under t hese conditions.

On occasion, the strong high pressure is weakly impacted by migrating low pressure systems over the Pacific Ocean. This has the dual effect of maintaining stagnant conditions over most of the region while allowing weak pressure systems to push air that is high above the surface eastward and to transport ozone trapped in this layer over long distances. The area most likely to be affected by this transport would be Clark County, Nevada.

Clark County, Nevada, has conducted an air quality monitoring study in which they evaluated ozone episodes in Las Vegas. This study suggests that ozone concentrations in Clark County were affe cted by ozone transported from sources in California. While ARB has no definitiv e data regarding the transport of ozone into Nevada, we are working together with the Clark County Department of Air Quality and Environmental Management to explore the issue further and have offered our efforts as they conduct the Southwest Desert/Las Vegas Ozone Transport Study this year.

PM2.5 : The technical support document for the PM2.5 designation of Lincoln County, Montana (containing Libby, Montana) found that the nonattainment area is “localized within and around the vici nity of the town of Libby due to topographical features and meteorology in the area impacted by emissions.” Therefore, Libby, Montana’s nonattainment status is not affected by emissions produced in other areas and transported to the Libby area.

It is important to note that whether or not emissions from California are transported to nonattainment areas in other states, California’s existing stringent motor vehicle control program, consumer product regulations, stationary source permitting, new source review programs, and new commitments outlined in the California SIP further strengthened by the 8-hour ozone and PM2.5 SIPs, will

1 Rule to Reduce Interstate Transport of Fine Pa rticulate Matter and Ozone (Interstate Air Quality Rule Preamble), 69 FR at 4581, January 30, 2004.September 21, 2007 Appendix C 3 result in steadily decreasing emissions. California’s emission control programs are the most sophisticated and aggressive in the country and will continue to push the air quality control envelope. Th is greatly reduces the likelihood that emissions from California will contribute significantly to nonattainment in any downwind state.

Evaluation of interference with Pr evention of Significant Deterioration Measures of any other State

U.S. EPA guidance 2 for interstate transport SIPs advises states to make a SIP submission to confirm that major sources in the Stat e are currently subject to prevention of significant deteriorati on (PSD) and nonattainment new source review (NNSR) preconstruction permi tting programs that apply to the 1997 8-hour ozone standard.

For the PM2.5 standard, the guidance adv ises states to provide a SIP submission to confirm that major sources in the St ate are subject to PSD and NNSR permitting programs impl emented in accordance wit h U.S. EPA’s interim guidance calling for use of PM10 as a su rrogate for PM2.5 in the PSD and NNSR
programs.

In California, all areas are subject to some form of preconstruction program for ozone and PM2.5. These rules are as stringent or more stringent than the federal preconstruction progr ams (PSD and NNSR). For ozone, California is on track to submit SIPs per the Phase II 8-hour Ozone Implementation Rule. For PM 2.5, California’s preconstructi on programs are being implemented in accordance with EPA’s interim guidance calling for the use of PM10 as a surrogate for PM2.5 emissions.

The following air districts are in attain ment of the 1997 feder al 8-hour ozone and PM2.5 standards and have a SIP approved PSD rule:

• Mendocino County Air Pollution Control District

• Monterey Bay Unified Air Pollution Control Dis trict

• Northern Sonoma County Air Pollution Control District

• North Coast Unified Air Quality Management District

• Sacramento Metro Air Quality Ma nagement District (PM2.5)

On a case-by-case basis, U.S. EPA has delegated partial PSD permitting authority to the following air districts that are in atta inment of t he 1997 federal 8-hour ozone and PM2.5 standards:

2 Guidance for State Implementation Plan (SIP) Submissions to Meet Current Outstanding Obligations Under Section 110(a)(2 )(D)(i) for the 8-Hour Ozone an d PM2.5 National Ambient Air Quality Standards , memo from William T. Harnett to Regi onal Air Division Directors dated August 15, 2006, Page 8.September 21, 2007 Appendix C 4 • Antelope Valley Air Quality Management District

• Bay Area Air Quality Management District

• San Diego Air Pollution Control District

For all other areas that are in attainm ent of federal standar ds, U.S. EPA retains federal PSD permitting authority.

The following air districts are nonatta inment of the 1997 federal 8-hour ozone standard and have new source review rules or are on track to submit NSR rules as part of their 8-hour ozone SIP developm ent process. These rules are or will be equivalent to or more stringent than the federal requirements.

• Antelope Valley Air Quality Managem ent District (Antelope Valley and Western Mojave Desert Nonattainment Area)

• Amador County Air Pollution Cont rol District (Central Mountain Counties Nonattainment Area)

• Bay Area Air Quality Management District

• Butte County Air Quality Management District

• Calaveras County Air Pollution C ontrol District (Central Mountain Counties Nonattainment Area)

• El Dorado County Air Pollution C ontrol District (Sacramento Federal Nonattainment Area)

• Feather River Air Quality Managem ent District (Sacramento Federal Nonattainment Area)

• Imperial Air Pollution Control District

• Kern County Air Pollution Control Dis trict (Eastern Kern Nonattainment Area)

• Mariposa County Air Pollution Co ntrol District (Southern Mountain Counties Nonattainment Area)

• Mojave Desert Air Pollution Control District (Antelope Valley and Western Mojave Desert Nonattainment Area)

• Northern Sierra Air Quality Management District (Western Nevada County Nonattainment Area)

• Placer County Air Pollution C ontrol District (Sacramento Federal Nonattainment Area)

• Sacramento Metropolitan Air Quality Management District (Sacramento Federal Nonattainment Area)

• San Joaquin Valley Unified Air Pollution Control District

• South Coast Air Quality Management District

• Tuolumne County Air Pollution C ontrol District (Southern Mountain Counties Nonattainment Area)

• Ventura County Air Poll ution Control District

• Yolo Solano Air Quality Managem ent District (Sacramento Federal Nonattainment Area)September 21, 2007 Appendix C 5 The following air districts are nonattain ment of the federal PM2.5 standard and already have NSR rules in place for PM 10. These rules ar e equivalent to or more stringent than the federal requirements:

• South Coast Air Quality Management District

• San Joaquin Valley Unified Air Pollution Control District

Evaluation of Interference with Othe r States’ Measures Required to Meet Regional Haze and Visibility SIP Requirements

U.S. EPA’s guidance 3 states that states and region al planning organizations are currently engaged in the task of identif ying Class I areas impacted by each state’s emissions and developing strategi es for addressing regional haze to be included in the States’ regi onal haze SIPs. Since thes e regional haze SIPs are not due until December 17, 2007, states will not be r equired to address this requirement until the Regional Ha ze SIPs are submitted.

California is on track to submit its R egional Haze SIP by December 17, 2007. The Regional Haze SIP will address interstate regional haze impacts.

3 Guidance for State Implementation Plan (SIP) Submissions to Meet Current Outstanding Obligations Under Section 110(a)(2 )(D)(i) for the 8-Hour Ozone an d PM2.5 National Ambient Air Quality Standards , memo from William T. Harnett to Regi onal Air Division Directors dated August 15, 2006, Page 9.