GOVERNING BOARD

Skip Barwick, Chair

Councilmember, City of Tulare 

Hub Walsh, Vice Chair

Supervisor, Merced County

Oliver L. Baines III

Councilmember, City of Fresno

Tony Barba

Supervisor, Kings County

Sally J. Bomprezzi

Councilmember, City of Madera

Dennis Brazil

Mayor, City of Gustine

Judith G. Case

Supervisor, Fresno County 

David Couch

Supervisor, Kern County

Bob Elliott

Supervisor, San Joaquin County

Harold Hanson

Councilmember, City of Bakersfield

William O’Brien

Supervisor, Stanislaus County

Alexander C. Sherriffs, M.D.

Appointed by Governor

Tom Wheeler

Supervisor, Madera County

J. Steven Worthley

Supervisor, Tulare County

Seyed Sadredin

Executive Director

Air Pollution Control Officer

Northern Region Office

4800 Enterprise Way 

Modesto, CA 95356-8718

(209) 557-6400 • FAX (209) 557-6475

Central Region Office

1990 East Gettysburg Avenue

Fresno, CA 93726-0244

(559) 230-6000 • FAX (559) 230-6061

Southern Region Office

34946 Flyover Court

Bakersfield, CA 93308-9725

(661) 392-5500 • FAX (661) 392-5585

www.valleyair.org

DATE: June 20, 2013

TO: SJVUAPCD Governing Board

FROM: Seyed Sadredin, Executive Director/APCO

Project Coordinator: Jessi Fierro

RE: ITEM NUMBER 11: QUANTIFICATION OF 

CONTINGENCY REDUCTIONS FOR THE 2008 

PM2.5 PLAN

RECOMMENDATION:

1. Authorize submittal of the “Quantification of Contingency 

Reductions for the 2008 PM2.5 Plan” to EPA; and

2. Authorize the Chair to sign the resolution for “Quantification of 

Contingency Reductions for the 2008 PM2.5 Plan.”

BACKGROUND:

The Clean Air Act (CAA) requires State Implementation Plans (SIPs) to 

include contingency measures, which are extra emission reductions 

that go into effect without further regulatory action if an area’s control 

strategy does not achieve sufficient emissions reductions to meet plan 

milestones, or if the area does not reach attainment on time. Extreme 

nonattainment areas like the San Joaquin Valley, which face significant 

air quality challenges, have developed several generations of 

aggressive and far-reaching emission reduction measures to meet 

various CAA requirements. The result of this “no stone left unturned” 

policy is that when viable emission reductions are identified, they are 

implemented to contribute to expeditious attainment. Reductions are 

not usually held in reserve for contingency, only to be used if the area 

fails to meet a milestone. As a result, contingency measure 

demonstrations in the Valley have been a challenge, historically, and 

the District has advocated for a more reasonable approach for 

addressing this requirement for areas with mature air quality programs. 

On November 9, 2011, EPA approved all components of the District’s 

2008 PM2.5 Plan except for the contingency measures, since EPA 
SJVUAPCD Governing Board

ITEM NUMBER 11: Quantification of Contingency Reductions for the 2008 PM2.5 Plan

June 20, 2013

2

concluded that, at that time, the amount of emissions reductions resulting from the 

plan’s contingency measures did not appear to be of sufficient quantity. In response to 

EPA’s action on the 2008 PM2.5 Plan, the District is required to submit a detailed 

quantification that demonstrates sufficient contingency emission reductions. The 

District’s “Quantification of Contingency Reductions for the 2008 PM2.5 Plan” 

demonstrates that sufficient contingency reductions are available for the 2008 PM2.5 

Plan through a combination of existing regulatory and incentive-based strategies. 

DISCUSSION: 

The discussion in EPA’s 2007 PM2.5 implementation rule suggests that the amount of 

contingency reductions should be equivalent to about “one year of reductions needed 

for the Reasonable Further Progress (RFP),” although this amount is not embodied in 

regulatory requirements related to contingency measures (40 CFR 51.1012 or CAA 

§172(c)(9)). The District’s “Quantification of Contingency Reductions for the 2008 

PM2.5 Plan” does not add any contingency measures to the plan, but it re-quantifies the 

available reductions to show that the contingency measures in the plan do in fact 

achieve reductions equivalent to “one year of reductions needed for RFP” for directlyemitted PM2.5, NOx, and SOx in 2015. 

Table 1 below summarizes how sufficient contingency reductions are available for 

PM2.5 and NOx. The District relies on three types of contingency measures for this 

quantification:

 Surplus from traditional regulations: Additional reductions occurring between 

2014 (the attainment year) and 2015 due to further implementation of ARBadopted mobile source controls and fleet turn-over was already quantified in 

EPA’s Technical Support Document (TSD) for the partial approval/partial 

disapproval of the PM2.5 plan.

 Regulations with contingency trigger: The District’s 2008 Amendment to Rule 

4901 (Wood Burning Fireplaces and Wood Burning Heaters) included a 

contingency provision that would lower the mandatory wood burning curtailment 

threshold if the Valley fails to attain the 1997 PM2.5 standard by April 2015. The 

District re-quantified the benefit of this contingency measure based on more 

recent and more accurate data.

 SIP-creditable incentives: The District’s successful incentive-based measures 

achieve significant emissions reductions and have not yet been credited in the 

plan for RFP or attainment modeling. New District Rule 9610 (State 

Implementation Plan Credit for Emission Reductions Generated through 

Incentive Programs), to be considered for adoption by your board in June 2013,

will supplement related EPA guidance and establish a mechanism for the District 

to take SIP credit for eligible incentive programs achieving surplus, quantifiable, 

and enforceable emissions reductions. 
SJVUAPCD Governing Board

ITEM NUMBER 11: Quantification of Contingency Reductions for the 2008 PM2.5 Plan

June 20, 2013

3

Table 1: Demonstration of Sufficient Contingency Reductions, PM2.5 and NOx

All reductions annual average tons per day (tpd), 2015

PM2.5 NOx

Contingency reductions required 2.5 31.6

Surplus from traditional regulations 0.0 21.0

Regulations with contingency trigger (Rule 4901) 3.12 0.3

SIP-creditable incentives* 0.10 4.15

Trade PM2.5 for NOx (1:9)** -0.72 6.48

Total contingency reductions achieved 2.5 31.93

Contingency need met? Yes Yes

* Up to 0.44 tpd of PM2.5 and up to 10.9 tpd of NOx are available from SIPcreditable incentives

** 1 ton of direct PM2.5 emissions reductions is equivalent to 9 tons of NOx

reductions in the 2008 PM2.5 Plan

FISCAL IMPACT:

There is no fiscal impact to the District as a result of this action. 

Attachments:

Attachment A: Resolution for Authorizing Submittal of the “Quantification of Contingency 

Reductions for the 2008 PM2.5 Plan” to EPA (5 pages)

Attachment B: Quantification of Contingency Reductions for the 2008 PM2.5 Plan (12 pages)