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 2 0 , 2013

TO: SJV UAP CD G overning B oard

FROM: Seyed Sadredin, Executive Director/APCO

Project Coordinator: Jessi Fierro

RE: ITEM NUMBER 11 : QUANTIFICATION OF

CONTINGENCY REDUCTIO NS 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 c ontingency measures

, which are extra emission reductions that go into effect wi t hout 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 a reas 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 implemente d 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, historicall y , 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 me asures, since EPASJV

U APCD Governing Board ITEM NUMBER 11: Quantification of Contingen cy Reductions for the 2008 PM2.5 Plan
June 20, 2013

2 concluded that, at that time, the amount of emissions reductions result ing 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 ye ar of reductions needed for RFP” for directly

emitted 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 ARB

adopted 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 p lan.

 Regulations with contingency trigger : The District’s 2008 Amendment to Rule 4901 (Wood Burning Fi replaces and Wood Burning Heaters) in cluded 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 conti ngency 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 adop tion by your board in June 2013,

will supplement related EPA guidance and establish a mechanism for the Distric t to take SIP credit for eligible incentive programs achieving surplus, quantifiable,

and enforceable emissions reductions.SJV

U APCD 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 o f PM2.5 and up to 10.9 tpd of NOx are available from SIP

creditable 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 (1 2 pages)