San Joaquin Valley Unified Air Pollution Control District April 16, 2015

Chapter 8: Commitment to Leave No Stone Unturned to Evaluate Additional Opportunities 

2015 Plan for the 1997 PM2.5 Standard 

Chapter 8

Commitment	to	Leave	No	Stone	Unturned	to	Evaluate	

Additional	Opportunities	

2015 Plan for the 1997 PM2.5 Standard

SJVUAPCD	

 

 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

Chapter 8: Commitment to Leave No Stone Unturned to Evaluate Additional Opportunities 

2015 Plan for the 1997 PM2.5 Standard 

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San Joaquin Valley Unified Air Pollution Control District April 16, 2015

8-1 Chapter 8: Commitment to Leave No Stone Unturned to Evaluate Additional Opportunities 

2015 Plan for the 1997 PM2.5 Standard 

Chapter 8: Commitment to Leave No Stone Unturned to Evaluate 

Additional Opportunities 

As discussed earlier, this 2015 Plan for the 1997 PM2.5 Standard (2015 PM2.5 Plan)

contains Most Stringent Measures, Best Available Control Measures, and ensures 

expeditious attainment. Furthermore, under Section 4.2 of Chapter 4, this plan commits 

to producing additional reductions in emissions to further expedite attainment. Despite 

the fact that this plan contains all the necessary elements for approval, the District is 

fully aware that meeting the tougher newer National Ambient Air Quality Standards 

require additional efforts and further reductions in emissions. 

Over the next year, the District must adopt State Implementation Plans (SIP) to address 

the 2006 PM2.5 Standard (of 15 μg/m3 annual and 35 μg/m3 24-hr) and the 2012 PM2.5 

Standard (of 12 μg/m3 annual and 35 μg/m3 24-hr). Additionally, the District must also 

develop a SIP for the 2008 Ozone Standard (of 75 ppb) by July 2016. As always, the 

District will leave no stone unturned to evaluate and identify further opportunities to 

advance attainment of the ever-tightening National Ambient Air Quality Standards. Of 

course, the opportunities identified to reduce emissions towards meeting these tougher 

standards may also help expedite attainment with the 1997 PM2.5 standard addressed 

by this plan. In developing these plans, the District will reevaluate all of its existing 

regulations and will explore all potential measures for all source categories. However, 

in the short term, the District commits to conduct the evaluations described below and to 

include any identified additional actions for reducing emissions and implementation 

schedules in the District’s attainment plan submission for the 2012 PM2.5 NAAQS in 

Fall 2016. Upon full approval of the 2015 PM2.5 Plan by EPA, these commitments will 

be enforceable by EPA as provided for under the Clean Air Act. 

 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

8-2 Chapter 8: Commitment to Leave No Stone Unturned to Evaluate Additional Opportunities 

2015 Plan for the 1997 PM2.5 Standard 

8.1 Rule 4311—Flares 

As demonstrated in Appendix C, District Rule 4311 already meets BACM and MSM 

requirements. However, due to the need to demonstrate attainment for multiple federal 

ozone and PM2.5 standards in the coming years and need to search for all available 

emissions reductions, the District commits to undertaking a comprehensive review of 

FMPs submitted under Rule 4311. The District commits to conduct the evaluation and 

have a draft report available for public review and commenting by December 1, 2015. 

After addressing public comments, the District commits to finalize this report by March 

31, 2016. This evaluation will be conducted in close coordination with flare operators in 

the Valley and will include the following elements: 

1. The District will review submitted FMPs to identify the most effective flare 

minimization practices utilized by operators to reduce flaring in various source 

categories and applications. Upon completion of review, the District commits to 

working closely with affected operators to evaluate and implement, when 

feasible, the most effective flare minimization practices through the FMP 

submittal and approval process under Rule 4311. 

2. The District will evaluate the technological achievability and economic feasibility 

of implementing new/additional minimization practices or technologies at affected 

facilities. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

8-3 Chapter 8: Commitment to Leave No Stone Unturned to Evaluate Additional Opportunities 

2015 Plan for the 1997 PM2.5 Standard 

8.2 Warm Mix Asphalt 

Emissions from asphalt usage are extremely small and do not significantly contribute to 

elevated PM2.5 levels in the Valley. However, due to the need to demonstrate 

attainment for multiple federal ozone and PM2.5 standards in the coming years and 

need to search for all available emissions reductions, the District commits to a number 

of actions to evaluate and promote the use of WMA in the Valley. The District commits 

to conduct the evaluation and have a draft report available for public review and 

commenting by December 1, 2015. After addressing public comments, the District 

commits to finalize this report by March 31, 2016. This evaluation will be conducted in 

close coordination with stakeholders (asphalt plant operators, Caltrans, city and county 

planning departments, ARB, EPA, and others) and will include the following elements: 

1. The District will evaluate opportunities to further encourage transportation and 

county agencies to continue transitioning from HMA to WMA as feasible. As part 

of this evaluation, the District will explore the potential feasibility of additional 

control measures and granting mitigation credits for WMA usage through the 

District’s Indirect Source Review (ISR) program. 

2. The District will evaluate potential outreach and education opportunities for 

encouraging project developers/construction managers to increase their adoption 

and implementation of WMA. 

8.3 Rule 4550—Conservation Management Practices 

As documented in Appendix C, District Rule 4550 already meets BACM and MSM 

requirements. It is also questionable that further opportunities for reducing PM2.5 

emissions exist. However, as stated earlier, in developing plans for the new and 

existing National Ambient Air Quality Standards, the District will reevaluate all existing 

regulations including Rule 4550 to evaluate all feasible opportunities for additional 

emissions reductions, if any. The District commits to conduct the evaluation and have a 

draft report available for public review and commenting by May 31, 2016. After 

addressing public comments, the District commits to finalize this report by October 15, 

2016. This evaluation will be conducted in close coordination with stakeholders 

(agricultural industry representatives, ARB, EPA, NRCS, farm bureaus, and others). 

 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

8-4 Chapter 8: Commitment to Leave No Stone Unturned to Evaluate Additional Opportunities 

2015 Plan for the 1997 PM2.5 Standard 

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