2008 PM2.5 Plan 

Chapter 4 

 

Strategic Concepts 
2008 PM2.5 Plan 

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Chapter 4: Strategic Concepts

4.1 INTRODUCTION 

This chapter discusses the District’s overall strategy for achieving emissions reductions 

and bringing the San Joaquin Valley into attainment of the federal PM2.5 and 8-hour 

ozone standards. The District’s overall approach relies on achieving the maximum 

reductions in the most expeditious manner possible. The approach relies on sound 

science and the best available technology. Given the magnitude of reductions needed 

to reach attainment and the associated challenges associated with such an effort, the 

District is implementing a four-faceted control strategy, described below. 

4.2 OVERALL APPROACH 

The District’s overall approach is concentrated on feasible measures that will get the 

most reductions. Each measure the District undertakes demands a significant 

allocation of staff time and opportunities for public participation, review, and comment. 

To improve the air as quickly as possible, control measures that are expected to yield 

the greatest health benefit will be undertaken first. 

The District must also approach control measures with sound science and the best 

available technologies. Achieving emissions reductions requires investment from local 

businesses and citizens. To ensure that investments will yield the desired returns, the 

District will support control development efforts with the scientific studies needed to 

substantiate the investments and efforts. In all cases, the District will rely on the latest 

advanced technology. 

4.2.1 Integration of Ozone and PM2.5 Strategies 

Since the San Joaquin Valley is also designated nonattainment for both the federal 

PM2.5 and 8-hour ozone standards, control strategies for PM2.5 and 8-hour ozone 

have been integrated and harmonized to the extent possible. NOx reductions from the 

ozone plan will also help reduce PM2.5 since NOx is a precursor to both ozone and 

PM2.5. Additional PM2.5 and SO2 reductions are also needed, though, to ensure 

attainment of the 1997 PM2.5 standard by 2014. Also, federal regulations (40 CFR 

51.1002) require PM2.5 Plans to identify and evaluate PM2.5 direct and SO2 controls to 

meet RFP and attainment goals. 
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4.3 FOUR-FACETED CONTROL STRATEGY 

Meeting the challenge of attaining the PM2.5 standard in the San Joaquin Valley, with 

its meteorological and topographical disadvantages as well as its growth rate and 

automobile-dependent land use patterns, will require an innovative approach that 

involves every person and business in the Valley. The centerpiece of the District’s 2008 

PM2.5 Plan is the control strategy, the measures that the District and others will put in 

place to control direct PM2.5 and precursor emissions in an effort to decrease 

concentrations of PM2.5, so that the San Joaquin Valley can attain the federal 

standards. 

To achieve this, the District is considering a four-faceted control strategy: 

 Regulatory Control Measures for Stationary Sources - The regulatory 

component will consist of traditional “command-and-control” regulations, like 

most current rules in the District’s Rulebook section titled, “Regulation IV – 

Prohibitions.” 

 Incentive-based Strategies - Incentive-based strategies will build on the 

District’s current grant programs, which use a combination of state and local 

funds. These programs have expanded in funding and increased in 

sophistication over the years. 

 Innovative Strategies and Programs – This part of the overall control strategy 

promotes innovative programs that are not traditional regulatory or incentive 

based strategies. Such innovative strategies achieve reduction of emissions 

from source categories not traditionally regulated by the District through 

alternative routes. 

 Local, State, and Federal Sources/Partnerships - This component of the 

Valley’s control strategy acknowledges that local, State, and Federal agencies 

must each reduce emissions from the sources under their jurisdiction to achieve 

sufficient NOx reductions. 

Each facet of the four-part control strategy will consist of a number of emission control 

measures, each of which will address specific source categories. 

The development of the District’s components of this strategy is based on twelve 

guiding principles:

Guiding Principles 

1. With public health as our number one priority, meet the federal ambient 

air quality standards as expeditiously as is practicable. 

2. Recognize that the Valley’s economic vitality and prosperity are 

essential to having the resources necessary to achieve our public 

health goals. 

3. Recognize that no “silver bullet” exists – every sector, from the public 

through all levels of government, business, and industry, must reduce 

emissions. 
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4. Achieve emission reductions in the most cost-effective way possible to 

get the “biggest bang for the buck.” 

5. When scheduling regulatory actions such as rules and strategies, allow 

adequate time for full public participation. 

6. Consider total impact on businesses; allow reasonable time for 

implementation of current and future rules. 

7. Give precedence to nitrogen oxides (NOx) emissions, as NOx 

emissions contribute to both ozone and PM formation. 

8. Take advantage of imminent new technologies and allow more time to 

get more reductions if needed. 

9. Do not let “one-size-fits-all” governmental policies and bureaucracy 

stand in the way of timely, innovative, and cost-effective emission 

reductions. 

10. Use sound science in assessing public health impacts, the magnitude 

of emissions from various source categories, and the availability, 

effectiveness, and feasibility of emissions control measures. 

11. Do not rely exclusively on the state and federal government to reduce 

mobile source emissions. Consistent with state and federal laws, find 

effective and innovative regulatory and incentive measures at the local 

level to address mobile source emissions.

12. Consider seasonal, episodic, and regional measures to more 

strategically target limited resources for optimum air quality benefits 

throughout the Valley.

4.4 LOCAL, STATE, AND FEDERAL COMPONENTS 

As discussed in Chapter 3, the District has limited jurisdiction over the NOx emissions 

inventory. The remaining portions of the inventory, which include mobile sources, 

pesticides and fertilizers, and consumer products, are under the jurisdiction of the state 

and federal governments. For more information on local, state, and federal controls, 

see Chapter 7. 

4.5 SUPPORT FROM OTHER DISTRICT PROGRAMS 

The success of District’s control strategy depends in part on the District’s compliance 

program. Programs like the District’s environmental review, public information, 

education, and outreach also contribute to the District’s successes in improving air 

quality. 

4.5.1 Compliance/Enforcement 
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The District operates a highly efficient and effective compliance program. The 

Compliance Division’s staff of 83 personnel maintains a strong presence in each of the 

District’s three regional service areas. The Compliance Division has a critical role in 

ensuring that rules and regulations relied upon to attain the NAAQS are fully enforced. 

The District uses several methods to increase compliance while maintaining a 

streamlined process. The first method to ensure compliance is education and outreach. 

Educational approaches include an extensive array of compliance assistance bulletins, 

written policies, compliance school for those who have received a notice of violation, 

training and workshops for specialized programs, participation in the Permit 

Streamlining Meetings, and, most importantly, one-on-one interaction with regulated 

sources during field inspections. 

A second method is the increased use of information technology. The District’s website, 

along with printed information, helps to ensure that the regulated community has full 

access to applicable regulations and instructions. The District is automating its 

permitting system to enable applicants to take advantage of streamlined applications for 

permits such as those required for agricultural burns. By making the process easier, 

compliance rates will be higher. 

The third method is the traditional field enforcement activities that include rigorous 

source tests, inspections, and response to complaints. The District has toll free 

complaint hot lines that enable the public to contact an on-call inspector at any time. 

The final approach falls into the District’s legal and Mutual Settlement area. District 

legal staff has the authority to issue large penalties as one of the strongest compliance 

incentives. 

“Compliance School” is offered as a voluntary educational training session to individuals 

and companies who have received a “Notice of Violation Settlement Letter” from the 

District. A person having the authority and responsibility to control the event that led to 

the violation of a District rule may qualify for a one-time penalty reduction by attending 

this two-hour education session. The first hour presents an overview of the air quality 

problems within the SJVAB. The second hour discusses rule requirements and 

provides recommendations regarding rule compliance. 

The Compliance Department has posted their policies on the District’s website for use 

by regulated sources as another educational tool. All new and modified policies are 

placed on the Web for public comment, and comments are incorporated into the policy 

when appropriate. Currently, there are 42 finalized policies on the District’s website for 

use by the public and regulated community and another seven policies in draft form.

The Compliance Department supports its efforts with 39 Compliance Assistance 

Bulletins and the continuous addition of others to assist regulated sources and the 

public. These bulletins are mailed out to affected sources, and they are posted on the 

District’s website. 
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On the District’s website, under Compliance Assistance, the following categories of 

information are available to assist regulated sources and the public: 

 Abrasive Blasting 

 Asbestos Requirements for Demolitions and Renovations 

 Bulletins 

 Burning 

 Dust Control 

 Gasoline Dispensing 

 INSPECT Program 

 Notice of Violation 

 Policies 

 Record Keeping Forms 

 Solvent Degreasing 

 Source Testing 

 Training Schedule 

 Variances 

4.5.2 Public Education, Awareness, and Information 

Engaging the public in efforts to reduce emissions is a key element of the PM 2.5 

attainment strategy. Education increases public support for new and controversial 

regulations. Helping people understand the complex issues underlying the PM 2.5 

problem further improves this support. Individuals can undertake many actions to 

reduce PM 2.5 emissions. When members of the public are aware that they can make 

a difference and are convinced that the problem is real, many people will change their 

behavior in a positive way. 

The District's education and information program has expanded and evolved over the 

years. It uses a variety of media, strategies, models and techniques to ensure the 

widest possible dissemination of air-quality information. It includes direct-marketing 

approaches with traditional media, including television, radio and print as well as new 

technologies, such as the District’s website and listserv emails, and non-traditional 

methods such as viral marketing. The District networks with other agencies, 

educational institutions, community organizations, industry groups and the news media 

in educational efforts. It produces educational materials such as videos, brochures, and 

fact sheets that provide focused information to targeted audiences. 

4.5.2.1 Programs 

Agriculture Outreach 

The District has a strong agriculture outreach component, reflecting the importance of 

this economic sector to the Valley air basin’s economy and to the ozone-attainment 
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strategy. The District works closely with the Valley’s agricultural industry leaders, 

leading to perhaps the most intensive research into agriculture-related emissions and 

conservation practices anywhere in the country. 

Agriculture Improving Resources (A.I.R.) is a partnership formed to aid agriculture in 

promoting voluntary improvement of air quality through scientifically proven, costeffective measures. Partners in A.I.R. include the District, the California Air Resources 

Board, California Cotton Ginners and Growers Associations, Nisei Farmers League, 

California Citrus Mutual, California Grape and Tree Fruit League, Raisin Bargaining 

Association, California Apple Commission, California Plant Health Association, Kern 

County Farm Bureau, Kings County Farm Bureau, Fresno County Farm Bureau, Tulare 

County Farm Bureau, Madera County Farm Bureau, Merced County Farm Bureau, 

Stanislaus County Farm Bureau and the USDA Natural Resources Conservation 

Service. This partnership will play an increasingly important role in providing 

information to growers on a wide variety of air-quality programs. 

The Dairy Permitting Advisory Group (DPAG) outreach effort was undertaken to 

address regulation of dairy emissions in compliance with a 2003 state law. Dairy 

industry stakeholders were concerned by the lack of scientific foundation for 

establishing emissions estimates and determining Best Available Control Technologies 

(BACT). Settlement for these concerns established a special commission to evaluate 

available scientific studies and advise the Air Pollution Control Officer on permitting and 

BACT determinations. DPAG membership included agency technical staff, scientists, 

stakeholder experts, and concerned citizens. All proceedings were conducted in public 

meetings with conference-call access. Scientists conducting new research, requested 

by the agencies to provide a sound basis for emissions-factor evaluation, appeared at 

proceedings and participated by phone and written communication in response to 

questions from the DPAG and public meeting participants. Results of this process were 

presented to the Air Pollution Control Officer (APCO) and reported to the District 

Governing Board. In addition to advising the APCO, the results of these proceedings 

defined additional research projects to fill remaining information gaps and refine 

emission measurements provided by the initial studies. 

Following review of the DPAG proceedings, the District developed Rule 4570 to address 

emissions from large confined animal facility operations (CAFO) and adopted the rule 

after holding public workshops and rule adoption hearings. Extensive public outreach 

has begun for the implementation of this rule. The District will be working with 

stakeholders to develop an outreach program for compliance assistance. The District 

works closely with farm bureaus in all eight counties to inform and update agriculture 

industry members on District activities and policy development. Extensive outreach to 

the agricultural community was also conducted on the CMP and Major Source (Title V) 

permitting programs. 

Spare the Air versus Healthy Air Living 

Spare the Air was a voluntary effort aimed at reducing air pollution on specific days 

when air quality was expected to be at its worst. While the Spare the Air program has 
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been successful at educating the public on key air quality issues, the understanding and 

interest in Valley air quality dictates that this program should evolve. 

The Healthy Air Living initiative is a lifestyle program aimed at giving businesses, 

communities, civic organizations, municipalities, health organizations, families and all 

Valley residents the tools they need to make substantial permanent lifestyle and 

behavior changes which will reduce emissions in the Valley year-round. 

. 

Clean Green Yard Machines 

The Clean Green Yard Machines program, the 

District’s annual lawnmower trade-in program, is 

one of the most popular programs administered 

by the District. This is a valuable component of 

the District’s overarching emissions reduction 

strategy, as gas-powered lawnmowers are a 

significant contributor to precursor emissions. 

The program represents a significant 

commitment of District resources, including 

advertising, planning and execution. The Clean Green Yard Machines program 

commands an extremely high level of media visibility, including positive editorial 

coverage by every daily newspaper in the District’s eight counties. 

Check Before You Burn 

The District’s Check Before You Burn Program is an educational 

program that supports the wood burning curtailment component of 

Rule 4901. As with other outreach programs, public-outreach 

information is regularly conveyed through cooperation with 

broadcast and print editorial media in all three regions. 

 
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Air Quality Index Forecasts 

The daily forecast for the Air Quality Index (AQI) (formerly known as the PSI – Pollutant 

Standards Index) is faxed and emailed directly to local television and radio stations, 

newspaper publications, as well as schools, health organizations, and others who have 

signed up to receive the notices. The forecast AQI helps educate the public about air 

pollution and advise residents when air quality is expected to be unhealthy, so they can 

modify their activities and protect their health. Although the number of unhealthy-air 

days is affected by many factors, the exceedingly low number of such days during 

2004-05 was in part attributed to a high level of public awareness and commensurate 

voluntary participation in emission-mitigating behaviors, as a result of pervasive publicity 

surrounding daily air-quality forecasts. The District’s staff meteorologists provide highly 

accurate air-quality predictions for the air basin. Forecasts now use more detailed 

information specific to the local daily conditions. 

Youth Education 

As part of the youth education program, the District’s Public Information staff makes 

frequent and regular presentations to schools within the District’s eight counties, ranging 

from pre-school through college, and at any time, day or night. Public Information staff is 

contacted frequently by school district officials to offer input on questions of student 

health during episodes of poor air quality and alternative activity suggestions. 

Furthermore, the District offers elementary, middle, and high school air-quality 

curriculum materials to all teachers in the San Joaquin Valley. The elementary school 

curriculum is accompanied by class material and incentive items, and focuses on 

general air-quality issues. The middle and high school curriculum focuses on mobile 

source emissions and is a science-based laboratory series. Public Information staff has 

also participated on a mentor basis for in-depth, long-term high-school science projects 

in specialized programs such as the Center for Advanced Research and Technology 

(CART), in the Fresno Unified and Clovis Unified school districts. Furthermore, the 

District has partnered with California State University at Fresno Division of Global and 

Continuing Education to offer a seven week college course on Air Quality Management. 

The District has also partnered with local organizations to distribute Air Quality Flag 

program materials to all schools in the Valley over the next few years. The multicolored flags are flown each day to indicate the forecast air quality. The program has 

accompanying materials that provide indoor activities for students on days when air 

quality is expected to be poor. Furthermore, the materials outline behavior 

modifications children and adults can take to help improve air quality. 

Bilingual Outreach 

The ability of the District to provide real-time translation services for a significant portion 

of the Valley’s population is a priority of utmost importance. Therefore, in 2007, the 

District’s Public Information section hired a second full-time staff member for Spanishlanguage outreach and translation activities. The District now has additional live 

translation capabilities, a service that has been used at board meetings, public 

meetings, the Town Hall meetings, and other events. Additionally, the District provides 
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Hmong-language and Punjabi-language information and outreach materials for the two 

major outreach programs: Healthy Air Living and Check Before You Burn. 

Media Relations 

The District maintains an effective and efficient media relations program, providing 

timely information to reporters and helping ensure news coverage accurately reflects 

the Air District’s position, actions, and rules. Staff members handle about 1,400 media 

inquiries annually from local, regional, national, and international news organizations. 

The District also provides a dedicated phone number for reporters who need information 

during non-work hours. District staff work to cultivate open communication with 

environment beat reporters to help them understand the air basin’s complex air-quality 

issues and encourage them to contact the Air District any time an air-quality story 

warrants District comment. 

Public Awareness Study 

In 2005, an extensive, broad-based marketing study was commissioned by the District 

to reveal and quantify the public’s level of air-quality knowledge, behavior adaptation to 

current air-quality information and general understanding of the District’s mission and 

activities. The study reported an exceptionally high level of understanding of air quality 

issues, which the research group attributed to successful public outreach by the District. 

4.5.2.2 Events 

Air-Quality Conferences 

The District organizes and executes an extensive air-quality conference every year. A 

wide variety of organizations, businesses, and individuals participate. More than 250 

representatives of business and industry, along with civic leaders, air-quality experts, 

health officials, and community activists, come together to discuss the Valley’s air 

challenges at the District’s Annual Air Quality Symposium. Outreach to inform the 

public on air quality research for ozone and particulates was expanded in 2006 through 

a free public symposium. “Central California Air Quality Research, How Science is 

Charting a Path to Cleaner Air” was co-sponsored by the District, ARB, and participants 

in the Central California air quality studies. The one-day conference provided 

information to the public developed by more than $60 million of research on ozone and 

particulates. Keynote speakers provided policy-relevant and technical findings of both 

the CCOS and the California Regional Particulate Air Quality Study (CRPAQS). Public 

questions were encouraged after each presentation, facilitated as needed by Spanish 

translation provided by District staff. Public interest in the symposium exceeded 

expectations and fully booked the capacity of the conference center. 

Town Hall Meetings 

Throughout the year, the District often hosts Town Hall meetings to educate and inform 

stakeholders and the general public about both short-term and long-term air quality 

goals and challenges. 
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These meetings are held in each region of the District and included rural locations, in 

order to include populations unlikely to attend regular meetings in urban settings. The 

District sends its highest-ranking officials and managers to make presentations and 

responds to public questions and comments: the APCO, Deputy APCO, Director of 

Planning and other key staff, as well as representation by Public Information 

administration. Additionally, live Spanish translation is provided. Public turnout has been 

exceptional. 

Other Events 

The District works with local groups such as the American Lung Association and 

rideshare agencies to promote annual events that reinforce clean-air activities. Some of 

the annual local and national events in which the District participates include: 

• Earth Day – local organizations sponsor various events, in April; 

• Clean Air Month – American Lung Association sponsors various events, in May; 

• Air Quality Awareness Week – sponsored by the U.S. Environmental Protection 

Agency, in May; 

• Rideshare Week – sponsored by local rideshare committees, in October; 

• Car Care Month – sponsored by the American Lung Association and Calif. State 

Automobile Association, in October. 

• Bike To Work Week – sponsored by the Fresno County Bicycle Coalition, in May. 

Many local activities are conducted by organizations and agencies throughout the 

Valley, including the annual Clean Air Business Expo, sponsored by Valley Clean Air 

Now; the World Ag Expo in Tulare; and the annual Conservation Fair by the County of 

San Joaquin. The District participates in these events and many others, and 

encourages activities that increase public awareness of air pollution and public 

participation in programs or activities to reduce air pollution. Many of the District 

activities can be found on its web site at www.valleyair.org.

4.5.2.3 Materials 

Informational Brochures 

The District continues to develop new and updated brochures to address air-quality 

issues in the air basin. Existing brochures and those under development include: 

 There is Money in the Air: information about emission-reduction incentive 

programs and how to apply 

 Healthy Air Living 

 Spare the Air 

 Hazard Reduction Burning 

 Indirect Source Review 

 NEAP: Natural Events Action Plan 

 Become a Spare the Air Employer Partner 

 Complaint Procedures 

 Understanding Air Toxics and Risk 
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 Aqueous Cleaning Solutions Used in Degreasing Operations 

 Lets’ Clear the Air!: discusses emissions from motor vehicles and provides 

practical tips on how to reduce those emissions, keep a car well tuned, and 

report smoking vehicles 

 Fact Sheet: in bullet points, discusses air-quality improvements and challenges, 

and details District program activities 

 Check Before You Burn: provides information on the District wood-burning rule 

and how to comply 

 Reg VIII: Fugitive Dust Control 

 Air Quality Natural Events Action Plan Episodes 

 Air Quality Flag Program 

 Leading the Way to a Clearer Future: provides general information about air 

quality, the Air District and how members of the public can help clear the air 

 Indirect Source Review: summarizes a rule designed to reduce emissions from 

new development in the SJVAB and informs developers how to comply 

 Clean-Air Yard Care: provides pollution-reducing tips for lawn and garden care 

Educational Videos 

A wide variety of educational videos are used to promote behavior change and to 

educate the public on air-quality issues. 

Newsletter 

Valley Air News is a monthly publication of the District and is widely distributed 

throughout the air basin. The newsletter highlights current activities of the District, 

summarizes Governing Board actions, commends efforts by Valley businesses to 

reduce air pollution beyond what is required, and discusses other relevant air quality 

issues. 

Board Highlights 

The District’s Board Highlights are distributed monthly as a one-sheet publication 

summarizing board activities and actions of that month. 

Public Service Announcements

Public Service Announcements (PSAs) have been created for use on television and 

radio stations throughout the air basin. These 30- to 60-second announcements remind 

the public to use public transportation, share rides to work, walk to lunch, buy 

nonvolatile consumer products, refrain from using their fireplaces on certain unhealthyair days, keep their vehicles properly tuned, use electric-powered lawn equipment, etc. 

4.5.3 Environmental Review 

The District reviews California Environmental Quality Act (CEQA) and development 

proposals received from cities, counties, and other agencies. Whenever development is 

planned or occurs, the District focuses on potential sources of emissions. Among the 

areas examined are agriculturally productive lands as they convert to non-agricultural 
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uses, construction and demolition activities, traffic-generating sources, and potential for 

facilities that may generate hazardous materials. The District developed two documents 

as resources for agencies to use when evaluating potential air quality impacts: the Air 

Quality Guidelines for General Plans (AQGGP) and the Guide for Assessing and 

Mitigating Air Quality Impacts (GAMAQI). The AQGGP is a guidance document and 

resource for cities and counties to use to address air quality in their general plans. 

Section 65302.1 of California Government Code requires cities and counties in the San 

Joaquin Valley to amend appropriate elements of their general plans to include data, 

analysis, comprehensive goals, policies, and feasible implementation strategies (such 

as those in the AQGGP) to improve air quality in their next housing element revisions. 

Cities and counties are required to submit these air quality amendments to the District 

for comment at least 45 days before adoption. 

The GAMAQI is an advisory document that provides lead agencies, consultants, and 

project applicants with uniform procedures for addressing air quality in environmental 

documents. Certain types of development projects are also reviewed under the 

District’s Indirect Source Review (ISR) Program, which reduces emissions of NOx and 

PM10 from new development projects. Other recent development projects have 

mitigated their air pollution impacts through voluntary development contracts with the 

District. 

4.5.4 Sustainable Incentives 

Alternative approaches for reducing emissions, as discussed in the following 

paragraphs, have been suggested for consideration by a number of parties. The District 

is considering how to work these ideas for alternative approaches into its control 

strategy where feasible. 

To promote the implementation of practices that reduce air pollution from a variety of 

sources, including exempt sources, industry suggested the development of sustainable 

incentives. The concept of sustainable incentives includes financial measures, 

programs, and/or prohibitory rule Advanced Emissions Reductions Options plans that 

provide an economic mechanism to fund air pollution reduction measures. Sustainable 

incentives may be in the form of private industry and/or foundation grants, federal 

and/or state government grants, tax credits, prohibitory rule incentives, and other 

programs. 

The concept of sustainable incentives is based upon existing programs such as the 

federal farm bill’s “Environmental Quality Incentives Program (EQIP); the State’s Carl 

Moyer Program; the District’s Heavy-Duty Program (see next section), and other 

programs that offset the implementation cost of pollution reduction measures. Many of 

these existing programs operate within the framework of a partnership involving private 

industry, the public, and public agencies. 
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As proposed by industry, the concept of sustainable incentives revolves around a 

market-based approach to pollution reduction using measures that are economically 

sound and that are supported by scientific research. Basic concepts could include: 

 Local air pollution control/air quality management districts, EPA, and ARB would 

assist local municipalities and other public agencies in acquiring additional 

funding. The funding would be used to implement emission reductions; expand 

existing incentive programs, such as EQIP and Carl Moyer; and offset mitigation 

cost needs of the local transportation agencies and communities. Such funding 

could be generated from either governmental sources in the form of grants or 

from industrial sources in the form of alternative compliance fees or penalties. 

 These regulatory agencies would consider suggestions for alternative emission 

reduction programs that generate equivalent emissions reductions to those 

identified in prohibitory rules, but are less costly to implement. Such programs 

would obtain emission reductions by contributing to other programs like EQIP, by 

reducing onsite emissions, or by allowing the use of valid emissions reductions 

from secondary sources located in the immediate vicinity of those sources 

seeking the use of the alternative emission reductions. Sustainable and other 

District incentives have demonstratively provided a more flexible route for 

emission reductions. 
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