San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

Chapter 4: Classification and Attainment
2015 Plan for the 1997 PM2.5 Standard 

# Chapter 4

Classification	and	Attainment

2015 Plan for the 1997 PM2.5 Standard SJVUAPCDSan Joaquin Valley Unified Air Polluti on Control District April 16, 2015

Chapter 4: Classification and Attainment
2015 Plan for the 1997 PM2.5 Standard This page intentionally blank.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

4-1 Chapter 4: Classification and Attainment
2015 Plan for the 1997 PM2.5 Standard 

### Chapter 4: Classification and Attainment

Until the exceptiona l weather conditions exp erienced due to the recent drought, the San Joaquin Valley (Valley) was on track to attain the 1997 annual PM2.5 standard before the federally mandated deadline o f December 2014. As discussed earlier in Chapter 1 and Appendix F, the Valley was on the verge of attaining the 19 97 federal PM2.5

national ambient air quality standard (15 μg/m 3 for annual, 65 μg/m 3 for 24-hour) with an average annual concentr ation of 14.7 μg/m 3 and average 24-hour concentration of 56.4 μg/m 3 in 2012 at the Valley’s historic peak PM2.5 sites in Bakersfie ld. The San Joaquin Valley Air Pollution Contro l District’s (District’s) 2008 PM2.5 Plan satisfied all federal implementation requirements fo r the 1997 PM2.5 standard at the time of adoption and

demonstrated attainment based on projected 2012-201 4 PM2.5 leve ls. All emission

reduction commitments under tha t plan have been fulfilled. Due to the extreme drought, stagnation, strong inversions, and historically dry conditions experienced over the winter of 2013-2014, analysis showed tha t the Valley could not reach a ttainment even if the Valley experienced zero PM2.5 pollution for the last three quar ters of 2014. Since the U.S. Environmental Protection Ag ency’s (EPA) policy does not al low for drought and stagnation to qualify as “except ional events” under the Clean A ir Act, the District was left with no choice but to reques t a bump-up in classification from Moderate
nonattainment to Serious nonattain ment, which was finalized for approval by EPA on April 7, 2015.

4.1 REQUEST FOR ATTAINMENT EXTENSION

As a Serious nonattainment ar ea, the Valley w ould have until De cember 31, 2015 to

attain the 1997 PM2.5 national ambient air quality standards (N AAQS) as determined using air monitoring data colle cted in calendar years 2013 thro ugh 2015. 1 Under federal Clean Air Act (CAA) Tit le 1, Part D, Subpart 4 (Subpart 4) Section (§) 188(e), upon application by any State, t he EPA may grant one extension of the attainment date of up to five years for a Seri ous nonattainment area beyond the date specified under CAA §188(c)(2). To be granted an extension, an area must show that it cannot attain by December 2015, but will attain as expeditiously as possible and no later than 2020.

In this plan, the District requests a one-time extension of the attainment deadline for the

24-hour standard to 2018 and the annual standard to 2020, based on the following findings:

4.1.1 Attainment by the December 31, 2015 Deadline is Impractic able

Design values (DV) represent the official metric for assessing air quality improvements and attainment of the NAAQS pe r the federal CAA and EPA regulat ions. Design value calculations are three-year a verages that follow EPA protocols for rounding, averaging conventions, data completeness , sampling frequency, data substi tutions, and data validity. The results provide consistency and transparency to determine basin-wide

1 U.S. Environmental Protection A gency (2012, March 2). Memorand um from the Office of Air Quality Pl anning and Standards: Implementation Guidance for the 2006 24- Hour Fine Pa rticle (PM2.5) Nationa l Ambient Air Quality Standards (NAAQS). Pages 14-15. Retrieved from http://www.epa.gov/ttn/naaqs/pm/ pdfs/20120302_imp lement_guidanc e_24-hr_pm2.5_naaqs.pdfSan Joaquin Valley Unified Air Polluti on Control District April 16, 2015

4-2 Chapter 4: Classification and Attainment
2015 Plan for the 1997 PM2.5 Standard attainment for both components of the 1997 PM2.5 NAAQS, includi ng the 24-hour
PM2.5 standard of 65 μg/m3 and the annual PM 2.5 standard of 15. 0 μg/m3. If any monitoring site within the air basin has either a 24-hour or an nual PM2.5 design value higher than the respective standar d, then the entire air basin is designated nonattainment. EPA provides det ailed guidelines and standards for the calculation 2 and data handling 3 methodologies.

For the Valley to attain the 1997 NAAQS for the years 2013-2015 , the monitoring data for this period would need to s atisfy both the 24-hour average and annual average attainment tests, which are based on 98 th percentile values and calendar year averages, respectively. Since the PM2.5 m onitoring data during this peri od was heavily influenced by the extreme drought conditions , long periods of stagnation, and strong inversions experienced during the winter of 2013-2014, as described in mor e detail below, the Valley cannot demonstrate atta inment of either component of the 1997 NAAQS by

December 2015.

Meteorology during the Winter Season of 2013-2014 In 2013, California experienced re cord-low precipitation and sn ow pack levels at only 20 percent of the normal amount of s now to provide water for the y ear. Specifically, in the Valley, 2013 represent ed the driest year since the start of rec ord keeping in 1895.

Extreme weather conditions over the winter of 2013-2014 overwhe lmed emissions controls and led to abnormally h igh PM2.5 levels. Because of t his, attainment of the

1997 annual and 24-hour PM2.5 s tandards based on 2012-2014 data is impossible. Furthermore, reclassification to S erious will not initially pro vide an attainment deadline that the Valley can meet, since the Serious deadline is based o n 2013-2015 data, which is also heavily affected by the high PM2.5 values recorded duri ng the winter period of

2013-2014.

Stable meteorology during the wi nter season can increase PM2.5 concentrations to high levels by providing strong tem perature inversi ons and low wind speeds (see Chapter 2). When this occurs, the PM2.5 concentrations during the winter mo nths of November to February can climb to very hi gh levels. The winter of 2013-201 4 experienced the strongest average atmospheric stabi lity over the last 15 years creating conducive
conditions for the formation and retention of high PM2.5 concen trations. This was the result of a persistent strong high pressure over the eastern Pa cific that effectively
blocked weather disturbances from entering California, which in hibited dispersion during November, December, and January.

In addition to the historically strong atmospheric stability, t he winter of 2013-2014 also experienced record low precipitat ion totals, with some location s breaking records over 100 years old. These unprecedent ed dry conditions exacerbated the air quality

2 Interpretation of the National Ambient Air Quality Standards f or PM2.5, 40 C.F.R. Pt . 50 Appendix N (2012).

Available at http://ecfr.gpoaccess.gov/cgi/t/text/textidx?c=ecfr&sid=9bdb7a34dcb75892aef9ee60b74da642&rgn=div9&view=t ext&node=40:2.0.1.1. 1.0.1.18.15&idno=40

3 Environmental Protect ion Agency [EPA]: Office of Air Quality P lanning and Standards. (1999, April). Guideline on Data Handling Conventions for the PM NAAQS (EPA-454/R-99-008). Retrieved from http://www.epa.gov/ttn/oarpg/ t1/memoranda/pmfinal.pdfSan Joaquin Valley Unified Air Polluti on Control District April 16, 2015

4-3 Chapter 4: Classification and Attainment
2015 Plan for the 1997 PM2.5 Standard challenge during the winter of 2013-2014. As a result of the e xtreme meteorology, the PM2.5 concentrations experienc ed in the Valley were the highest recorded in over a

decade.

1997 Annual PM2.5 NAAQS As background, the 1997 annual aver age PM2.5 standard was set a t 15.0 μg/m 3 . The design value (DV) for the annual PM2.5 standar d, which is the o fficial EPA metric used

to determine whether an area is i n attainment of a standard, is defined as the 3-year average of annual averages over thr ee consecutive years. Each individual annual average is calculated as the av erage among the four quarterly a verages throughout the year. For example, the 2015 design value would be calculated a s the average among the annual averages for the y ears 2013, 2014, and 2015, where t he average of each of these individual years is calcu lated as the average among their respective quarterly averages. If the final annual av erage DV for all of the regula tory PM2.5 monitoring sites for the 3-year period is l ess than or equal to 15.0 μg/m 3 , then the area would be in
attainment of the standard.

Because both 2013 and 2014 PM2.5 c oncentrations were influenced by the extreme
weather of the 2013-14 winter s eason, the 2015 annual averages would have to be improbably low in the southern portion of the Valley in order f or the 2013-2015 period to satisfy the annual average attain ment test. To show this impro bability, the District

determined the maximum annual PM2 .5 average needed in 2015 to b ring each air quality monitoring site into a ttainment during the 2013-2015 pe riod. This determination was made by first estimating t he 2014 values with the best avai lable information. On January 16, 2015 the District pul led data from t he EPA Air Qual ity System (AQS) to

estimate the 2014 values. Most val ues in the “2014 Estimated” column of Table 4-1 were determined using 2014 AQS data when ava ilable, and prelimi nary data was used for the remainder of the year. S ites marked with an asterisk w ere calculated using 4 th

Quarter 2013 PM2. 5 Data because 4 th Quarter 2014 filter data was unavailable at the
time of this 2015 PM2.5 Plan . The maximum annual PM2.5 average in 2015 needed to bring each site into attainm ent during the 2013-2015 period was then subsequently

calculated. These results are displayed in Table 4-1.

The sites in Hanford, Visalia-C hurch, and Bakersfield-Californi a would all have to have a 2015 annual average under 10 μg/m 3 (historical data demonstr ates that the Valley is not likely to achieve these annua l averages). With the 2013 an d 2014 PM2.5 data from Bakersfield-Planz, the site is al ready out of attainment of the annual standard, without including the 2015 data. Based on this impossibility, the Vall ey cannot reach attainment of the annual average portion of t he 1997 PM2.5 st andard during the 2013-2015 period. This demonstrates the long reac hing ramifications that one seas on of unusually high

values due to the extreme weather can have on a region’s abilit y to reach attainment.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

4-4 Chapter 4: Classification and Attainment
2015 Plan for the 1997 PM2.5 Standard Table 4-1 Maximum Allowable PM 2.5 Annual Averages Needed in 20 15 to Reach
Attainment of Annual Standard in 2013-2015

Site 2013

Measured Actuals 2014

Estimated 2015
Max Allowable for

Attainment

Stockton-Hazelton 17.7 12.3 15.0

Manteca 11.6 9.9 23.5

Modesto 14.3 11.6 19.1

Turlock 15.0 12.6 17.4

Merced-M* 13.5 13.6 17.9

Merced-Coffee 13.3 10.9 20.8 Madera-City 17.8 14.2 13.0

Clovis 15.9 15.3 13.8

Fresno-Garland 16.8 15.3 12.9 Fresno-Winery* 15.9 16.8 12.3 Tranquility 8.3 7.9 28.8

Corcoran* 15.6 16.6 12.8

Hanford 18.2 17.2 9.6

Visalia-Church 18.9 16.7 9.4

Bakersfield-California 20.0 17.9 7.1

Bakersfield-Planz* 22.8 24.6 -2.4
*Calculated using 4 th Quarter 2013 PM2. 5 Data, 2014 4 th Quarter filter data unav ailable at th is time. All other sites, used 2014 AQS data when available, preliminary data was used for the remainder of the year.

1997 24-Hour PM2.5 NAAQS The 1997 24-hour average PM2. 5 standard was set at 65 μg/m 3 . The DV for the 24- hour average PM2.5 standard, is def ined as the 3-year average o f annual 98 th
percentile values over three cons ecutive years. Each individua l annual 98 th percentile value is calculated by ranking the 24-hour average values withi n a year and selecting the value corresponding with the 98 th percentile. The 98 th percentile values for each individual year over the 3-year period are averaged to produce the final DV. For example, the 2015 design value would be calc ulated as the avera ge among the 98 th
percentile values for the y ears 2013, 2014, and 2015. If the f inal annual average DV for all of the regulatory PM2.5 monitoring site s for the 3-year per iod is less than or equal to 65 μg/m 3 , then the area would be in a ttainment of the standard.

The maximum 98 th percentile 24-hour average PM2. 5 concentrations in 2015 needed to bring each air quality monitoring site into attainment during t he 2013-2015 period were calculated using a methodology s imilar to that discussed above. First, the 2014 values were estimated using data pulled from the EPA AQS on January 16 , 2015. Most values
in the “2014 Estimated” column o f Table 4-2 were determined usi ng 2014 AQS data when available, and preliminary data was used for the remainder of the year. Sites

marked with an asterisk we re calculated using 4 th Quarter 2013 PM2.5 Data because 4 th

Quarter 2014 filter data was unavailable at the time of this 2015 PM2.5 Plan . The

maximum 98 th percentile 24-hour average PM2. 5 concentrations in 2015 need t o bring

each site into attainment dur ing the 2013-2015 period was then subsequently
calculated. Refer to Table 4-2 for the results of this analysi s.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

4-5 Chapter 4: Classification and Attainment
2015 Plan for the 1997 PM2.5 Standard As with the annual average dat a, because both 2013 and 2014 wer e influenced by the extreme weather of 2013-2014, the 2015 averages would have to b e improbably low in the southern portion o f the Valley. The Bakersfield-Planz air monitoring site would need

to have a 98 th percentile 24-hour PM2.5 c oncentration of 15.9 μg/m 3 for 2015 to show attainment for the three year a verage. Historical data demonst rates that the Valley is extremely unlikely to achieve th ese averages for 2015. Based o n this impossibility, the Valley cannot reach attainmen t of the 24-hour average portion o f the 1997 PM2.5 standard during the 2013-2015 period.

Table 4-2 Maximum Allowable 98 th Percentile 24-Hour Average PM2.5
Concentrations Needed in 2015 to Reach Attainment of 24-Hour
Standard

Site 2013

Measured Actuals 2014

Estimated 2015
Max Allowable for

Attainment

Stockton-Hazelton 56.3 44.5 95.4

Manteca 40.2 40.0 116.0

Modesto 56.4 49.5 90.3

Turlock 55.4 51.0 89.8

Merced-M* 67.3 57.2 71.7

Merced-Coffee 42.3 43.9 110.0 Madera-City 54.6 56.1 85.5

Clovis 56.2 59.0 81.0

Fresno-Garland 63.8 65.5 66.9 Fresno-Winery* 71.6 71.6 53.0 Tranquility 35.7 31.2 129.3

Corcoran* 66.0 71.0 59.2

Hanford 67.6 82.0 46.6

Visalia-Church 62.5 74.0 59.7

Bakersfield-California 71.8 80.0 44.4

Bakersfield-Planz* 96.7 83.6 15.9
*Calculated using 4 th Quarter 2013 PM2. 5 Data, 2014 4 th Quarter filter data unav ailable at th is time.
All other sites used 2014 AQS data when available, preliminary data was used for the remainder of the year.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

4-6 Chapter 4: Classification and Attainment
2015 Plan for the 1997 PM2.5 Standard 4.1.2 All Requirements and Commi tments in the Implementation Pl an Have Been

Met

As detailed in Chapter 6, the Dis trict has met or exceeded all requirements contained in

the 2008 PM2.5 Plan and the emissions reductions a chieved exceed the emission reduction commitments in the plan.

ARB has also met or exceeded a ll requirements and emission redu ction commitments

contained in the 2008 PM2.5 Plan, and a detailed description w ill be included in ARB’s supporting documentation for the plan’s adoption by ARB, schedu led in May.

4.1.3 The 2015 PM2.5 Plan Contains Best Available Control Measures (BACM)

Chapter 5 and Appendix C contai n detailed analyses of all poten tial measures for all source categories consistent with federal guidance and past pre cedents. Going beyond applicable federal requirements, t his analysis even examined th e application of BACM to source categories that were found to be below federal de min imis thresholds. This analysis indicates that the Distric t meets or exceeds BACM requ irements for all source categories.

4.1.4 The 2015 PM2.5 Plan Contains Most Stringent Measures (MSM)

Chapter 5 and Appendix C contai n detailed analyses of all poten tial measures for all source categories consistent with federal guidance and past pre cedents. Going beyond applicable federal requirements, t his analysis even examined th e application of MSM to source categories that were foun d to be below federal de minimi s thresholds. This analysis indicates that the Distr ict meet or exceeds MSM requir ements for all source categories.

4.1.5 The 2015 PM2.5 Plan Includes a Demonstration of Attainment by the Most Expeditious Alternative Date Practicable

Attaining federal health-based air quality standards is an impo rtant milestone for improving public health. As det ailed in Appendix F, this 2015 PM2.5 Plan demonstrates that the Valley will attain the federal 1997 PM2. 5 standard as expeditiously as possible,
with all feasible measures and st rategies being implemented to accomplish this goal. Through ongoing implement ation of the contro l strategy containe d in the 2015 PM2.5

Plan , the Valley will come into att ainment of the 24-hour standard by 2018, and the annual standard by 2020.

The Role of NOx Reductions in Assi sting Valley Reach Attainment Given the significant contributi on of ammonium nitrate to the V alley’s PM2.5 concentrations, reductions in NOx emissions are particularly im portant. To achieve the
NOx reductions critical for reac hing attainment in the Valley, ARB has adopted regulations that will significant ly reduce NOx emissions from v arious mobile sources. Achieving this level of emi ssions reductions requires adequate time and carries a

tremendous cost.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

4-7 Chapter 4: Classification and Attainment
2015 Plan for the 1997 PM2.5 Standard The District’s “no stone unturned” evaluation of emissions sour ces and emissions

controls demonstrate that the mo st stringent measures, which i ncludes all reasonably available emission reduction opp ortunities and best available c ontrol measures, are in place in the Valley.

The attainment demonstration for this 2015 PM2.5 Plan includes the benefits of ARB and District control programs tha t provide ongoing emission red uctions. Continued implementation of these control programs provides new emission reductions each year, resulting in a forecasted 38 per cent decrease in NOx emissions and a five percent

decrease in PM2.5 emissions betw een 2012 and 2020.

The NOx reductions result from ongoing implementat ion of both n ew vehicle standards for passenger and heavy-duty dies el vehicles and equipment, as well as rules accelerating the turnover of l egacy diesel fleets. Implementat ion of stringent requirements for new off-road en gines and in-use off road equip ment lead to further NOx reductions, along with Distric t rules addressing stationary source NOx emissions.

PM2.5 emission reductions resul t from ongoing implementation ofdiesel on- and offroad equipment measures as well as the District’s recently stre ngthened rule for woodburning fireplaces and heaters.

Attainment Demonstration Modeling The attainment demonstration approach for this 2015 PM2.5 Plan is based on modeling
conducted for the 2008 PM2.5 Pl an, which also addressed the 199 7 annual and 24-hour PM2.5 standards. The atmospheric dynamics and associated resp onse to emission reductions represented in this m odeling, coupled with 2013 desi gn values (DV) and chemical composition, was used to project future (2020 for the annual standard and
2018 for the 24-hour standar d) design values.

To assess the representativeness of the 2008 SIP m odeling for c apturing the dynamics and response to emission reducti ons for the updated attainment demonstration, ARB evaluated both the meteorological characteristics, as well as t he chemical composition used in the two modeling effort s and found that they are very s imilar. Therefore, the

2008 PM 2.5 SIP modeling response to emissi on reduction, applied to 2013 DV s, provides a suitable basis for the updated attainment demonstrat ion.

To ensure consistency wit h the approved 2008 PM2.5 SIP modeling, the current effort uses a single DV representing 2013 based on ambient measurement s during 2011- 2013. The base emission year is the middle year of 2012, with future emission years of
2020 for the annual standard attain ment demonstration, and 2018 for the 24-hour

standard demonstration.

Due to the differences in base years (2005 for the 2008 PM2.5 Plan vs. 2012 for the

2015 PM2.5 Plan ) and future years (2014 vs. 2018 or 2020), the RRFs calculated for the 2008 modeling canno t be used directly in the current Plan. Thus, the updated modeling uses scaled RRFs pres ented in the following equation.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

4-8 Chapter 4: Classification and Attainment
2015 Plan for the 1997 PM2.5 Standard ܴܴܨ ଵଶିଶ଴ ൌ ൤1 െ ሺ 1 െ ܴܴܨ ଴ହିଵସ ሻ ൈ %∆ܧ ଵଶିଶ଴ %∆ܧ ଴ହିଵସ ൨

Here,

%∆ܧ ଵଶିଶ଴ ൌ ܧ ଵଶ െ ܧ ଶ଴
ܧ ଵଶ ൈ 100%	ܽ݊݀	%∆ܧ ଴ହିଵସ ൌ ܧ ଴ହ െ ܧ ଵସ
ܧ ହ଴ ൈ 100%,

where, E j is the total emissions for a gi ven emissions component for yea r j ( = 2005, 2012, 2014, and 2020). That is, quantities in the above equat ion represent percent emissions changes for the curr ent and 2008 Plans. Similarly, R RF i-k represents RRF values for the current (2012- 2020) and 2008 Plans (2005-2014).

Modeling Results Eight of the fifteen sites in t he Valley recorded 2013 DVs over the annual PM 2.5 standard of 15 μg/m 3 . The higher DVs occurred in the Valley’s southern region (inc luding the
Bakersfield and Visalia as well as Hanford) and the central reg ion (around the Fresno urban area and Madera). Only one site in t he northern region ( Turlock) measured a

2013 DV over the standard. All sites in the SJV recorded 2013 DVs at or below the 24- hour standard of 65 μg/m 3 . In 2020, all sites in the Vall ey are projected to attain the

annual standard. For those sites that exceeded the standard, t he projected 2020 DVs range from 12.5 μg/m 3 to 15.0 μg/m 3

.

This section intentionally blank.San Joaquin Valley Unified Air Pollution Control DistrictApril 16, 20154-9Chapter 4: Classification and Attainment2015 Plan for the 1997 PM2.5 StandardTable 4-3 Projected 2020 Annual and 2018 24-hour Design ValuesMonitoring SiteAQS SiteIDTypeSpeciation2013 Ann.DV12020 Ann.DV withRules12013 24-hr DV22018 24-hrDV withRules2Bakersfield - California Street 060290014 FRMBakersfield-California16.4 13.7 64.6 51.6Bakersfield - 410 E Planz 060290016 FRMBakersfield-California17.0314.3 55.8344.9Clovis - N Villa Avenue 060195001 FRM Fresno-1st16.4413.3 57.6445.3Fresno - 1st Street/Garland5FRM Fresno-1st15.4512.5 62.0549.3Fresno - Hamilton and Winery 060195025 FRM Fresno-1st14.7 12.0 63.5 50.3Hanford-S Irwin Street 060311004 FEM-BAM Visalia- N Church 17.0 13.9 60.2 45.8Madera 060392010 FEM-BAMFresno-1st18.1 15.0 52.3 41.4Manteca-530 Fishback Rd 060772010 FEM-BAM Modesto 14th10.2 8.7 36.7 32.1Merced - 2334 M Street 060472510 FRM Modesto 14th11.1 9.2 49.2 40.3Merced – S Coffee Ave 060470003 FEM Modesto 14th13.3 11.0 41.8 34.8Modesto - 14thStreet 060990005 FRM Modesto 14th13.6 11.5 50.6 42.2Stockton - Hazelton Street 060771002 FRM Modesto 14th13.8 12.0 45.0 39.0Tranquility 060192009 FEM-BAM Fresno-1st7.9 6.6 30.0 23.9Turlock-S Minaret Street 060990006 FEM-BAM Modesto 14th15.7 13.2 52.7 43.8Visalia - N Church Street 061072002 FRM Visalia - N Church 16.613.5 55.7 42.51. Design values equal toor less than 15.0 μg/m3attain the annual PM2.5standard2. Design values equal toor less than 65.4 μg/m3attain the 24-hour PM2.5standard3. Does not include 167.3 μg/m3measured on May 05, 2013 (supporting documentation provided inAttachment B)4. Clovis 2013 DV is based oncombined FRM/FEM BAM data5. 2013 DV is based on2011 data for Fresno-1st(060190011) and 2012/2013 datafor Fresno-Garland (060190008)San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

4-10 Chapter 4: Classification and Attainment
2015 Plan for the 1997 PM2.5 Standard 4.2 COMMITMENT TO ACHIEVE EX TRA REDUCTIONS IN EMISSIONS

As discussed earlier, the 2015 PM2. 5 Plan contains Most Stringe nt Measures, Best
Available Control M easures, and ensures expeditious attainment. However, the District
and the California Air Resources Board are committed to leaving no stone unturned to ensure attainment of this impor tant health-based standard as ra pidly as possible. Towards that end, this plan cont ains commitments for the follow ing additional reductions

in emissions:

1. Replace Heavy Duty Trucks – Using motor vehicle surcharge funds generated by the District under AB 2522, the District commits to allocati ng $10,000,000, for the period of 2016 through 2020. T hese funds will be used towa rds the replacement of heavy duty trucks in the San Joaquin Valley thro ugh the District’s truck replacement incentive prog ram, achieving emissions reduct ions surplus to
the State Truck and Bu s Regulation.

a. Amount of Funding: $10,000,000; for perio d of 2016 through 2020

b. Number of Trucks Replaced: 152 - 200

c. Surplus Emissions R eductions Achieved: 0.25 – 0.33 tons NOx/day

2. Replace Residential Wood burning Devices – Through the use of locallygenerated funding, the District co mmits to allocating $7,500,00 0, for the period of 2016 through 2020. These funds will be used towards the replac ement of old high polluting residentia l wood burning devic es in the San Joaq uin Valley through
the District’s Burn Cleaner Inc entive Program, achieving emissi ons reductions surplus to District Rule 4901.

a. Amount of Funding: $7,500,000; for period of 2016 through 2020

b. Number of Devices Replaced: 4,000 – 7,500

c. Surplus Emissions Re ductions Achieved: 0.1 – 0.4 tons of PM2.5 per day

3. ARB Commitments for Additional Reductions – In addition to the above commitments by the District for additional reductions in emissi ons, ARB has also committed to do their part by co mmitting to provide additional reductions in
emissions for sources under thei r control. ARB staff will prop ose a commitment on actions for key truck se ctors in the Valley to:

a. Better ensure benefits from t he Truck and Bus regulation, an d b. Pursue opportunities for the replacement of trucks certified to the State’s optional low NOx standard.