2008 PM2.5 Plan 

## Chapter 4

Strategic Concepts2008 PM2.5 Plan This page intentionally blank.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Chapter 4: Strategic Concepts

2008 PM2.5 Plan 4-1 

## 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 atta inment of the feder al PM2.5 and 8-hour

ozone standards. The District’s overall approach relies on achieving the maximum reductions in the most expeditious m anner possible. The approach relies on sound science and the best available technology. Given the magnitude of reductions needed

to reach attainment and the associated c hallenges associated with such an effort, the District is implementing a four-facet ed control strategy, described below.

4.2 OVERALL APPROACH

The District’s overall approach is concentra ted 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 partici pation, review, and comment. To improve the air as quickly as possible, c ontrol 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 inve stments will yield the desired returns, the District will support control dev elopment efforts with the sci entific 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 Oz one and PM2.5 Strategies

Since the San Joaquin Valley is also des ignated nonattainment for both the federal

PM2.5 and 8-hour ozone standards , control strategies fo r PM2.5 and 8-hour ozone have been integrated and harmonized to the ext ent possible. NOx reductions from the ozone plan will also help reduce PM2.5 sinc e NOx is a precursor to both ozone and

PM2.5. Additional PM2.5 and SO 2 reductions are also needed, though, to ensure

attainment of the 1997 PM2.5 standard by 2014. Also, f ederal regulations (40 CFR 51.1002) require PM2.5 Plans to ident ify and evaluate PM2.5 direct and SO 2 controls to meet RFP and attainment goals.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Chapter 4: Strategic Concepts

2008 PM2.5 Plan 4-2 4.3 FOUR-FACETED CONTROL STRATEGY

Meeting the challenge of at taining the PM2.5 standard in the San Joaquin Valley, with its meteorological and topographi cal 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 Va lley. The centerpiece of the District’s 2008

PM2.5 Plan is the control strategy, the measures that the Dis trict and others will put in place to control direct PM2.5 and precur sor emissions in an effort to decrease concentrations of PM2.5, so that the San Jo aquin Valley can attain the federal

standards.

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

 Regulatory Control Measures for Stationary Sources - The regulatory component will consist of traditional “c ommand-and-control” regulations, like

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

Prohibitions.”

 Incentive-based Strategies - Incentive-based strat egies will build on the District’s current grant pr ograms, which use a combi nation of st ate and local funds. These programs have exp anded 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 regulat ory or incentive based strategies. Such innovative strat egies achieve reduction of emissions from source categories not traditional ly regulated by the District through

alternative routes.

 Local, State, and Federal Sources/Partnerships - This component of the Valley’s control strategy acknowledges t hat local, State, and Federal agencies

must each reduce emissions from the source s under their jurisdiction to achieve
sufficient NOx reductions.

Each facet of the four-part c ontrol strategy will consist of a number of emission control measures, each of which will address specific source categories.

The development of the Distr ict’s components of this strategy is based on twelve guiding principles:



### Guiding Principles

1. With public health as our number one pr iority, meet the federal ambient air quality standards as expeditio usly as is practicable.

2. Recognize that the Valley’s eco nomic 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, bus iness, and industry, must reduce

emissions.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Chapter 4: Strategic Concepts

2008 PM2.5 Plan 4-3 4. Achieve emission reductions in the most cost-effective way possible to get the “biggest bang for the buck.”

5. When scheduling regulatory actions su ch 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 oxid es (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 stat e and federal government to reduce

mobile source emissions. Consist ent 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 resource s 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 por tions of the inventory, whic h include mobile sources, pesticides and fertilizers, and consumer products , are under the jurisdiction of the state and federal governments. For more informati on on local, state, and federal controls, see Chapter 7.

4.5 SUPPORT FROM OT HER DISTRICT PROGRAMS

The success of District’s control strategy depends in part on the District’s compliance program. Programs lik e 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/EnforcementSan Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Chapter 4: Strategic Concepts

2008 PM2.5 Plan 4-4 The District operates a highly efficient and effective compliance program. The Compliance Division’s staff of 83 personnel ma intains 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 regulatio ns 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 thos e 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 in teraction with regulated sources during field inspections.

A second method is the increased use of info rmation technology. The District’s website, along with printed information, helps to ens ure that the regulat ed community has full access to applicable regulations and instruct ions. The District is automating its permitting system to enable applicants to take advantage of streamlined applications for permits such as those required for agricultu ral burns. By making the process easier, compliance rates will be higher.

The third method is the traditional field enfor cement 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 Settlem ent area. District legal staff has the authority to issue large penalties as on e of the strongest compliance

incentives.

“Compliance School” is offered as a voluntar y educational training session to individuals and companies who have received a “Notice of Violation Settlement Letter” from the District. A person having the aut hority 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 ho ur 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 educationa l tool. All new and modified policies are placed on the Web for public comment, and co mments are incorporated into the policy when appropriate. Currently, there are 42 finaliz ed policies on the District’s website for use by the public and regulat ed community and another seven policies in draft form.

The Compliance Department supports it s 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.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Chapter 4: Strategic Concepts

2008 PM2.5 Plan 4-5 On the District’s website, under Complianc e 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 effort s to reduce emissions is a key element of the PM 2.5 attainment strategy. Educ ation increases public suppor t for new and controversial regulations. Helping people understand t he complex issues underlying the PM 2.5 problem further improves this support. I ndividuals can undertake many actions to

reduce PM 2.5 emissions. W hen 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 progr am has expanded and evolved over the years. It uses a variety of media, stra tegies, models and techniques to ensure the widest possible dissemination of air-quality information. It incl udes direct-marketing approaches with traditional media, including te levision, radio and print as well as new technologies, such as the District’s webs ite and listserv emails, and non-traditional methods such as viral marketing. The District networks with other agencies, educational institutions, community organiza tions, industry groups and the news media in educational efforts. It produces educatio nal materials such as videos, brochures, and fact sheets that provide focused in formation to targeted audiences.

4.5.2.1 Programs

Agriculture Outreach
The District has a strong agriculture outreac h component, reflecting the importance of this economic sector to the Valley air basin’s economy and to the ozone-attainmentSan Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Chapter 4: Strategic Concepts

2008 PM2.5 Plan 4-6 strategy. The District works closely with t he Valley’s agricultural industry leaders, leading to perhaps the most intensive rese arch 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 improvem ent of air quality through sci entifically proven, costeffective measures. Partners in A.I.R. incl ude the District, the Ca lifornia Air Resources Board, California Cotton Ginners and Grow ers Associations, Nisei Farmers League, California Citrus Mutual, California Gr ape and Tree Fruit League, Raisin Bargaining Association, California Apple Commission, Ca lifornia Plant Health Association, Kern County Farm Bureau, Kings County Farm Bu reau, 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 va riety of air-quality programs.

The Dairy Permitting Advisory Group (DPA G) 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 determi ning Best Available Control Technologies (BACT). Settlement for these concerns established a special commission to evaluate

available scientific studies and advise t he Air Pollution Control Officer on permitting and BACT determinations. DPAG membership incl uded agency technical staff, scientists, stakeholder experts, and concerned citizens. All proceedings were conducted in public meetings with conference-call access. Sci entists conducting new research, requested by the agencies to provide a sound basis fo r emissions-factor evaluation, appeared at proceedings and participated by phone and wri tten communication in response to questions from the DPAG and public meeting parti cipants. Results of this process were presented to the Air Pollution Control Offi cer (APCO) and reported to the District Governing Board. In additi on to advising the APCO, the results of these proceedings defined additional research projects to fill remaining information gaps and refine emission measurements provi ded by the initial studies.

Following review of the DPAG proceedings, t he District developed Rule 4570 to address emissions from large confined animal fac ility operations (CAFO) and adopted the rule after holding public workshops and rule adopti on 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 wo rst. While the Spare the Air program hasSan Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Chapter 4: Strategic Concepts

2008 PM2.5 Plan 4-7 been successful at educating the public on ke y air quality issues, the understanding and interest in Valley air quality dictat es that this program should evolve.

The Healthy Air Living initiative is a lif estyle program aimed at giving businesses, communities, civic organizations, municipalit ies, health organizations, families and all Valley residents the tools they need to ma ke substantial permanent lifestyle and behavior changes which will reduce emi ssions 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. T he 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 outr each programs, public-outreach information is regularly conveyed through cooperation with broadcast and print editorial media in all three regions.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Chapter 4: Strategic Concepts

2008 PM2.5 Plan 4-8 Air Quality Index Forecasts
The daily forecast for the Air Quality Index (AQI) (formerly known as the PSI – Pollutant Standards Index) is faxed and em ailed 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 foreca st 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 ex ceedingly low number of such days during 2004-05 was in part attributed to a high le vel of public awareness and commensurate voluntary participation in emi ssion-mitigating behaviors, as a re sult of pervasive publicity surrounding daily air-quality forecasts. The Dis trict’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 wit hin 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 offici als to offer input on questions of student health during episodes of poor air quality and alternative activity suggestions.

Furthermore, the District offers element ary, middle, and hi gh school air-quality

curriculum materials to all teachers in t he San Joaquin Valley. The elementary school curriculum is accompanied by class materi al and incentive items, and focuses on general air-quality issues. The middle and high school curriculum focuses on mobile

source emissions and is a sci ence-based laboratory series. P ublic 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 Un ified school districts. Furthermore, the District has partnered with Cali fornia 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 or ganizations to distribute Air Quality Flag program materials to all schools in the Va lley over the next fe w 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. Furt hermore, 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-tim e translation services for a significant portion of the Valley’s population is a priority of utmost importanc e. 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 ev ents. Additionally, the District providesSan Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Chapter 4: Strategic Concepts

2008 PM2.5 Plan 4-9 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 effici ent media relations program, providing timely information to reporters and helping en sure news coverage accurately reflects the Air District’s position, actions, and ru les. Staff members handle about 1,400 media inquiries annually from local, regional, national, and inter national 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 under stand the air basin’s complex air-quality issues and encourage them to contact the Air District an y time an air-quality story

warrants District comment.

Public Awareness Study

In 2005, an extensive, broad-based marketi ng 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 un derstanding of the District’s mission and activities. The study reported an exceptionall y 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 extens ive air-quality conference every year. A wide variety of organizations, businesses, and individuals participate. More than 250 representatives of business and industry, al ong 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 par ticulates 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-spons ored by the District, ARB, and participants in the Central California air quality st udies. The one-day conference provided information to the public developed by mo re than $60 million of research on ozone and particulates. Keynote speakers provided poli cy-relevant and technical findings of both the CCOS and the California Regional Particul ate Air Quality Study (CRPAQS). Public questions were encouraged after each present ation, facilitated as needed by Spanish translation provided by District staff. P ublic 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 pu blic about both short-term and long-term air quality goals and challenges.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Chapter 4: Strategic Concepts

2008 PM2.5 Plan 4-10 These meetings are held in each region of t he District and included rural locations, in order to include populations unlikely to atte nd regular meetings in urban settings. The District sends its highest-ranking official s and managers to make presentations and responds to public questions and comment s: the APCO, Deputy APCO, Director of Planning and other key staff, as well as representation by Public Information administration. Additionally, live Spanish tran slation is provided. Public turnout has been exceptional.

Other Events
The District works with local groups su ch 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 wh ich the District participates include:

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

• Clean Air Month – American Lung Associat ion 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 Am erican 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 Bu siness 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 r educe 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 broc hures and those under dev elopment include:

 There is Money in the Air: inform ation 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 Ai r Toxics and RiskSan Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Chapter 4: Strategic Concepts

2008 PM2.5 Plan 4-11  Aqueous Cleaning Solutions Us ed in Degreasing Operations

 Lets’ Clear the Air!: discusses emissi ons 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, discusse s air-quality improvem ents and challenges, and details District program activities

 Check Before You Burn: provides info rmation 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 polluti on-reducing tips for lawn and garden care

Educational Videos
A wide variety of educational videos ar e used to promote behavior change and to educate the public on air-quality issues.

Newsletter Valley Air News is a monthly publicati on of the District and is widely distributed throughout the air basin. The newsletter highlig hts current activities of the District, summarizes Governing Board actions, comm ends 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 dist ributed monthly as a one-sheet publication summarizing board activities and actions of that month.

Public Service Announcements
Public Service Announcements (PSAs) hav e 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, shar e rides to work, walk to lunch, buy nonvolatile consumer products, refrain from using their fi replaces on certain unhealthyair days, keep their vehicles properly tuned, use electric-powered lawn equipment, etc.

4.5.3 Environm ental Review

The District reviews California Environment al 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-agriculturalSan Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Chapter 4: Strategic Concepts

2008 PM2.5 Plan 4-12 uses, construction and demolition activities, traffic-generating sources, and potential for facilities that may generate hazardous mate rials. The District developed two documents as resources for agencies to use when evalua ting potential air quality impacts: the Air Quality Guidelines for General Plans (AQGGP) and the Gu ide 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 citi es and counties in the San Joaquin Valley to amend appropriate elements of their general plans to include data, analysis, comprehensive goals, policies, and f easible implementation strategies (such as those in the AQGGP) to improve air qualit y in their next housing element revisions. Cities and counties are required to submit these air qualit y amendments to the District for comment at least 45 days before adoption.

The GAMAQI is an advisory document that pr ovides lead agencies, consultants, and project applicants with uniform procedures fo r addressing air quality in environmental documents. Certain types of development projects are also reviewed under the District’s Indirect Source Review (ISR) Pr ogram, which reduces emissions of NOx and PM10 from new development pr ojects. Other recent de velopment 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 part ies. 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, industr y 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 In centives Program (EQI P); 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 par tnership involving private industry, the public, and public agencies.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Chapter 4: Strategic Concepts

2008 PM2.5 Plan 4-13 As proposed by industry, the concept of su stainable 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 pub lic agencies in acquiring additional funding. The funding would be used to im plement 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 consi der suggestions for alternative emission reduction programs that generate equival ent emissions reductions to those identified in prohibitory ru les, but are less costly to implement. Such programs would obtain emission reductions by contri buting to other programs like EQIP, by reducing onsite emissions, or by allowin g the use of valid emissions reductions from secondary sources located in the immediate vicinity of those sources seeking the use of the alternative em ission reductions. Sustainable and other District incentives have demonstratively provided a more flexible route for

emission reductions.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Chapter 4: Strategic Concepts

2008 PM2.5 Plan 4-14 This page intentionally blank.