# Proposed Draft: May 2010



# 2010 Ozone

Mid-Course ReviewSan Joaquin Valley Unified Air Pollution Control Di strict 1990 E. Gettysburg Avenue Fresno, California 93726

(559) 230-6100

www.valleyair.orgExecutive Summary i 

### 2010 Ozone Mid-Course Review

Executive Summary

The San Joaquin Valley’s surrounding mountains, sta gnant weather patterns, and hot summers provide the ideal conditions for ozone form ation. However, despite this uniquely difficult topography and meteorology, the San Joaquin Valley Air Pollution Control District (District) has a history of succes sfully developing and implementing

control measures to reduce both 1-hour and 8-hour o zone concentrations in the Valley.

In order to achieve these successes, the District d eveloped robust regulatory, incentive, outreach, and education strategies in their 2004 Extreme Ozone Attainment Demonstration Plan (EOADP) and 2007 Ozone Attainment Demonstration Plan (2007

Ozone Plan ). Both of these plans were developed using comput er modeling, extensive public input, which included over 15 workshops and Town Hall Meetings involving over 300 Valley residents, and extensive research into a ll feasible control options. Each plan included a comprehensive and exhaustive list of reg ulatory and incentive-based measures to reduce emissions of ozone and particula te matter precursors throughout the Valley. Consistent with the direction of each plan , the Governing Board adopted regulatory measures that, in the majority of cases, exceeded the plan commitment for a given source category, especially through the imple mentation of the Confined Animal Facilities Rule (4570), Phase II of the Stationary Internal Combustion Engines Rule (4702), Stationary Gas Turbines Rule (4703), and mu ltiple rules for Boilers, Steam Generators, and Process Heaters (4307, 4306, 4320). Overall, rules in the EOADP achieved 15.8 tons per day more NOx and 11.7 tons p er day more VOC than committed to in the plan; and rules in the 2007 Ozone Plan achieved 8.0 tons per day more NOx and 3.2 tons per day more VOC than committed to in the plan.

Additionally, the plans included consideration of f uture advancements in pollution control technologies and increases in state and federal fun ding for incentive-based measures as options to achieve the “black box” reductions. The “black box” reductions are an estimated 82 tons per day of NOx reductions needed by December 31, 2023 to achieve the ozone standard. These reductions depend on the use of technologies, funding sources, and strategies that were not available at the time of plan development and adoption. Thus far, such innovative strategies and new technologies have enabled the

District to achieve more emissions reductions than originally projected at the time of plan adoption. These surplus reductions reduce the size of the “black box” in the 2007 Ozone

Plan

.

Many of the rules implemented through the EOADP and 2007 Ozone Plan , such as the Indirect Source Review (ISR) rule, are the first of their type in the nation, or are deemed the most stringent in the nation. The District’s ( ISR) Rule bridges the gap between regulations and incentives to maximize reductions w hile minimizing socioeconomic impacts. The ISR rule requires developers of new d evelopment projects to reduce emissions during both the construction and operatio nal phases of the project. The District works closely with developers to maximize on-site emissions reductions at the proposed developments; however, if developers are n ot able to fully mitigate requiredii SJVAPCD 2010 Ozone Mid-Course Review

reductions through on-site measures, fees may be co llected to fund off-site emission reduction projects. To date, the District has spen t approximately $2 million in ISR fees to achieve over 1,172 tons of nitrogen oxides (NOx) em issions reductions and 43 tons of particulate matter (PM) emission reductions.

The District’s strategy to reduce emissions also in cludes the proactive use of incentives

to obtain reductions that would otherwise not be co st-effective for industry or are outside the District’s regulatory authority. Over the twel ve years of active incentive program implementation, NOx and volatile organic compound ( VOC) emissions have been reduced by 71,814 tons and 2,501 tons, respectively . In addition to the emissions saved, the District was successful in bringing more than $ 213 million in grant funding into the Valley to support not only emissions reductions, bu t also the advancement of new technology and the regional economy. The District is working with EPA to make the incentive programs SIP creditable so that these red uctions could be used to reduce the

“black box” emission reduction commitment.

The District’s development and implementation of in novative strategies and outreach programs such as the Healthy Air Living Program, Fa st Track Action Plan, and the Regional Energy Efficiency Strategy, have enlisted the voluntary participation of individuals, governmental agencies, businesses, and private citizens throughout the Valley to take actions to reduce NOx and VOC for im proved air quality. While implementing and fostering these activities is no t rivial task on the part of the District in terms of time and commitment, they can be fairly ea sy to implement for the public sector given the appropriate information and valuable deci sion-making tools. In fact, in many instances such as reducing energy use and reducing vehicle miles traveled, consumers

can also reduce their costs – a “win-win” for the D istrict and the Valley.

The District has aggressively promoted technology a dvancement strategies. The recently approved Technology Advancement Program (T AP) will help ensure a comprehensive and collaborative approach to involvi ng all segments of the Valley in realizing attainment of the ozone and other health standards.

In addition to developing strategies and a roadmap to attainment, the 2007 State Implementation Plan (SIP) committed the District to submit a Midcourse Review (MCR) by June 30, 2010. This MCR must evaluate the progr ess that the District has made towards attaining the 1997 8-hour ozone national am bient air quality standard (NAAQS) and the revoked 1-hour ozone NAAQS. Although the 1 -hour ozone NAAQS was revoked in 2005, the anti-backsliding provisions in the imp lementation rules for the 8-hour NAAQS require the District to continue to implement most commitments previous set under the 1- hour ozone NAAQS, including progress reports and at tainment of the standard. In this MCR, staff assessed, at a basin-wide level, recent trends in emissions estimates, monitored air quality data, and other corroborating analyses to demonstrate that the District’s strategies are resulting in emissions re ductions and air quality improvement
needed to attain both ozone NAAQS.

Since ozone concentrations are highly dependent on weather conditions staff adjusted the trends for long-term weather patterns showing t hat decreasing trends in ozoneExecutive Summary iii

concentrations are a result of successful regulator y and voluntary emissions reductions programs, not simply favorable weather conditions. Through District efforts, the Valley

continues to be on-track to reach attainment of bot h the 1-hour and 8-hour ozone NAAQS by or before the applicable attainment deadlines.

The path towards attainment is being further accele rated by Valley industry and municipal investments in cleaner technologies and emissions r eductions implemented at the state and local level. These included over 20 regulation s developed by the California Air Resources Board (ARB) in the last 3 years, numerous transportation control measures implemented by the metropolitan planning organizati ons, and many measures implemented by the federal government that were not included in either ozone attainment plan.

The District expects air quality to continue to imp rove as recent regulations are fully implemented, new control technologies are developed , and increased partnership between government and private entities occurs thro ugh programs such as Healthy Air Living, the Fast Track Action Plan, Regional Energy Efficiency Strategy, and the Technology Advancement Program. The District’s pas t successes and commitments to the community are documented annually in the Annual Report to the Community , which is published each year in the fall or winter. The most recent year’s report is included as

an attachment to this MCR.

Despite this success and anticipated attainment of the current 8-hour ozone standards, the challenge continues. On January 6, 2010, EPA, in a effort designed to protect public health, proposed to strengthen the NAAQS for 8-hour ozone from the 1997 85 parts per billion (ppb) standard to a level within the range of 60 to 70 ppb. Additionally, on December 18, 2006, EPA changed the 24-hour NAAQS fo r particulate matter with an aerodynamic diameter of 2.5 microns or less (PM2.5) from 60 micrograms per cubic meter ( μ g/m 3 ) to 35 μ g/m 3 . These two changes trigger a requirement for the District to develop new attainment demonstration plans for 8-ho ur ozone and PM2.5 in the 2013 timeframe, which may include many of the regulation s, incentive measures, and innovative strategies included in our current ozone plans. The achievements highlighted in this 2010 Ozone Midcourse Review, particularly f or NOx, which is a precursor to both ozone and PM2.5, will assist the District in meetin g these new, more stringent standards. Building upon the momentum for reductions from inno vative strategies, new technologies, and partnerships with industry and the public the V alley can all look forward to a future of improved health and quality of life for Valley resi dents and attainment of not only the revoked 1-hour and current 8-hour ozone standards, but also the future 8-hour ozone and
new PM2.5 NAAQS.iv SJVAPCD 2010 Ozone Mid-Course Review This Page Intentionally BlankTable of Contents v 2010 Ozone Mid-Course Review

Table of Contents

Section 1 - Background and Summary.................

................................................... ...... 1

1.1 Background .........................................

................................................... .......................1

1.2 Health and Economic Effects of Ozone ...............

................................................... .......2

1.3 Mid-Course Review Summary ..........................

................................................... ..........4

Section 2 - Air Quality & Regional Growth Trends...

................................................... . 5

2.1 Emission Trends....................................

................................................... .....................5

2.2 Air Quality Trends.................................

................................................... ......................7

2.2.1 Ozone Design Values ................................

................................................... ............8

2.2.2 Ozone Exceedance Days ..............................

................................................... ......10

2.2.3 8-hr Ozone Expected Peak Day Concentration (EPDC).. ........................................12

2.3 Evaluation of Ozone Trends Adjusted for Weather .... ..................................................1 4

2.3.1 Meteorological Adjusted Ozone Trend Methodology.... ...........................................14

2.3.2 Meteorological Adjusted Ozone Trend Interpretation . .............................................15

2.4 Growth Trends in Population & Vehicle Miles Travele d................................................23

2.5 Summary of Air Quality and Regional Growth Trends.. ................................................24

Section 3 - Regulatory Control Measures ............

................................................... .... 25

3.1 Implementation of Stationary Source Regulatory Cont rols...........................................25

3.2 Feasibility Studies................................

................................................... .....................28

3.2.1 Internal Combustion Engine (ICE) Electrification/Pu mp Efficiency Incentives .........30

3.2.2 Prescribed Burning .................................

................................................... .............31

3.2.3 Open Burning Biomass Incentive.....................

................................................... ....31

3.2.4 Crude Oil Production Sumps.........................

................................................... .......32

3.2.5 Heavy Crude Oil Components .........................

................................................... ....33

3.2.6 Solid Fuel Fired Boilers...........................

................................................... .............33

3.2.7 Small Boilers......................................

................................................... ..................34

3.3 Summary of Regulatory Control Measures .............

................................................... ..34

Section 4 - Indirect Source Review.................

................................................... .......... 35

4.1 On-Site Emissions Reductions & Off-Site Emissions M itigation ...................................36

4.2 Mitigation Fees for Incentives .....................

................................................... ..............36

4.3 Summary of ISR .....................................

................................................... ..................37

Section 5 - Incentive Programs.....................

................................................... ............ 39

5.1 Ongoing Incentive Programs .........................

................................................... ...........39

5.2 Incentive Programs in Development ..................

................................................... .......41

5.2.1 Technology Advancement Program (TAP)............... ...............................................41

5.2.2 Air Quality Action Center for Technology & Innovati on for the Valley ......................42

5.2.3 Energy Efficiency Funding Opportunities ............

................................................... .42

5.2.4 Other State Funding Opportunities..................

................................................... .....42

5.3 State Implementation Plan Creditability for Incenti ve Programs...................................42

5.4 Summary of Incentive Program Success ...............

................................................... ...43vi SJVAPCD 2010 Ozone Mid-Course Review

Section 6 - Innovative Strategies ..................

................................................... ............ 45

6.1 Healthy Air Living.................................

................................................... .....................45

6.2 Fast Track Measures................................

................................................... ................45

6.2.1 Advanced Emission Reduction Options (AERO)......... ............................................46

6.2.2 Alternative Energy .................................

................................................... ..............46

6.2.3 Energy Conservation ................................

................................................... ...........47

6.2.4 Episodic & Regionally-Focused Controls .............

................................................... 47

6.2.5 Green Contracting ..................................

................................................... .............48

6.2.6 Green Fleets.......................................

................................................... .................48

6.2.7 Heat Island Mitigation .............................

................................................... .............48

6.2.8 High Speed Rail....................................

................................................... ...............49

6.2.9 Inland Ports and Short Sea Shipping ................

................................................... ...49

6.2.10 Truck Replacement/Retrofit .........................

................................................... ........49

6.3 Technology Advancement Program.....................

................................................... .....50

6.4 Other Public Education, Awareness & Information....

................................................... 50

6.5 Summary of Innovative Strategies ...................

................................................... .........50

Section 7 - Federal, State & Local Controls........

................................................... ..... 53

7.1 State & Federal Controls ...........................

................................................... ...............53

7.2 Local Government Commitments & Achievements ........ ..............................................54

7.2.1 Regional Transportation Plans......................

................................................... .......55

7.2.2 Conformity Budgets .................................

................................................... ............55

7.2.3 Congestion Mitigation Air Quality (CMAQ) Program... .............................................56

7.3 Summary of Federal, State & Local Controls .........

................................................... ...57Section 1 – Background & Summary 1 

## Section 1 - Background and Summary

The San Joaquin Valley Air Pollution Control Distri ct (District) has prepared this 2010

Ozone Mid-Course Review (MCR) to demonstrate to the United States Environm ental Protection Agency (EPA) that the District has met i ts obligations under the Federal Clean Air Act (CAA), as amended in 1999, for progress tow ards attaining the revoked 1-hour and 1997 8-hour ozone national ambient air quality standards (NAAQS). The California Air Resources Board (ARB) committed to conduct an 8 -hour ozone MCR and, if appropriate, submit the MCR to EPA by June 30, 2010 as part of the District’s 2007 State Implementation Plan (SIP).

This review includes an assessment of the ozone air quality trends in the San Joaquin Valley Air Basin (Valley), a summary of all control measure commitments included in the District’s ozone attainment demonstration plans, an d the estimated reductions achieved by these measures. This review concludes that the District’s efforts, along with the Valley’s business’ and residents’ efforts, have red uced ozone precursors as seen in the

continued downward trend of ambient ozone concentra tion levels and that the District is on track towards meeting attainment of the ozone NA AQS by the applicable attainment

dates.

Despite the fact that the EPA revoked the 1-hour oz one NAAQS, effective June 15, 2005, many federal requirements in effect as of the date of revocation continue to apply under the anti-backsliding provisions of the 8-hour ozone NAAQS implementation rules, including a requirement to attain the 1-hour ozone NAAQS per the 2004 Extreme Ozone

Attainment Demonstration Plan ( EOADP

). Since the District continues to implement control measures identified in the adopted EOADP, in addition to those in the 2007

Ozone Plan

for the 8-hour ozone NAAQS, this MCR will include data for both the 1-hour and 8-hour NAAQS and associated attainment plans.

1.1 Background Pursuant to the CAA, the EPA designated the Valley as nonattainment for the current 1- hour and 8-hour ozone NAAQS, with an extreme classi fication and associated attainment dates of November 15, 2010 and end-of-year (EOY) 20 23, respectively. The District

submitted the EOADP

and the 2007 Ozone Plan to demonstrate anticipated attainment of the current 1-hour and 1997 8-hour ozone NAAQS, res pectively. In developing the attainment plans for these ozone NAAQS, the Distric t utilized photochemical modeling, air quality trend analysis, and other corroborating evidence to demonstrate that adopted, mandated, and voluntary control measures and additi onal commitments would provide

emissions reductions sufficient to enable all areas of the Valley to achieve attainment by

attainment dates for the two ozone standards. The District has a history of success in reducing ozone precursors; through the effectivenes s of the groundbreaking rules, such as Indirect Source Review, Confined Animal Faciliti es, wine fermentation, and industrial combustion equipment, the California Air Resource B oard (ARB) documented a 42 percent reduction in NOx emissions and a 37 percent reduction in VOC emissions from 1990 through 2005, Valley-wide.2 SJVAPCD 2010 Ozone Mid-Course Review

The 2007 Ozone Plan

implemented expanded and innovative control measur es and strategies to overcome the significant challenge in attaining both the 1-hour and 8-hour plans. Under the EPA implementation rule for the 1 -hour NAAQS there is an opportunity for a one-year extension of this attainment date, i f the prior year shows clean air quality data. This provision allows for a nonattainment ar ea to reach attainment of the standard, despite the fact the area had one year in the three years prior to attainment that showed higher than typical ozone levels due to a higher th an typical number of wildfires, meteorological patterns, and/or other events. In o rder to receive this one-year extension an air district must demonstrate to EPA that the pr evious year’s ozone levels meet the 1- hour NAAQS in accordance with the implementation ru le.

The demonstration of attainment for both the 1-hour and 8-hour ozone NAAQS takes into account the significant natural challenges in the V alley, which are unmatched in any other region of the nation. While the Valley is one of t he most fertile agricultural regions in the world, its geomorphology and meteorology exacerbate the formation and retention of high levels of air pollution. The Valley is bounded by the Sierra Nevada on the east, the Tehachapi Mountains on the south, and the Coastal a nd Temblor Ranges on the west creating a “horseshoe” valley open to the northwest ; this geomorphology, together with consistently stagnant weather patterns, both during hot summers and foggy winters, prevents the dispersal of pollutants that accumulat e within the Valley. The satellite photograph in Figure 1-1 demonstrates the manifesta tion of these significant natural challenges during the winter months; the trapped ai r layer not only includes fog, but undispersed pollutants. In the extremely hot summe r months, the Valley is often capped with a temperature inversion layer that further tra ps ozone and ozone precursors, causing high ozone concentrations throughout the summer.

1.2 Health and Economic Effects of Ozone Understanding the empirical health benefits and mod eling the potential economic benefits of reductions in ambient ozone exposure provides de cision makers and the public with valuable information for finding the critical balan ce that regulatory agencies such as the District must maintain between public health protec tion and economic viability. Additionally, decision makers and the public must h ave a mechanism to evaluate the progress of an adopted attainment plan, such as the 2007 Ozone Plan

. Figure 1

- 1
San Joaquin Valley Air Basin during winter meteorological stagnation event.Section 1 – Background & Summary 3

Considerable research over the past 35 years docume nts the physical effects of ozone

inhalation on humans. These studies have consisten tly shown that ozone can lead to inflammation and irritation of airway tissue. Brea thing ozone can also reduce lung function and inflame lung epithelial lining. Sympt oms and responses to ozone exposure vary widely among individuals. Typical symptoms in clude cough, chest tightness or pain, shortness of breath, pain when taking a deep breath , coughing, throat irritation, congestion, and increased asthma symptoms

Children are most at risk from exposure to ozone. Children breathe more air per pound of body weight than adults and because children’s r espiratory systems are still developing, they are more susceptible to air pollut ants. The Children’s Health Study funded by the California Air Resources Board found that ozone may contribute to the development of asthma in children who play sports o utdoors. 1 Ground-level ozone is highest in the summertime, when children spend much of their day outdoors, thus disproportionately increasing their ozone risk rela tive to adults. While children are certainly affected by exposure to summertime ozone, anyone who spends time outdoors during times of increased ozone levels may be impac ted as well.

Ozone in sufficient concentrations increases the pe rmeability, or “leakiness” of lung cells, making them more susceptible to environmental toxin s and infection caused by microorganisms such as viruses and bacteria. In ep idemiological studies, ozone exposure has been associated with an increase in ho spital admissions and emergency room visits, particularly for pulmonary trauma, suc h as asthma and chronic obstructive pulmonary disease (COPD). Elevated ozone exposure has also been shown to be positively associated with premature death from res piratory disease in a recent study of 448,850 subjects in 96 U.S. cities. 2 Equally significant, a study of over 6,000 Califo rnia births found that elevated ozone exposure during pr egnancy was correlated with reduced fetal growth among term infants. 3

These health impacts carry economic costs as well. In The Health and Related Economic Benefits of Attaining Healthful Air in the San Joaquin Valley

, researchers Jane V. Hall, Victor Brajer, and Frederick Lurmann (2006 ) report that the economic benefits of meeting the 1997 federal standard for ozone in the Valley could save a total of more than $88.9 million annually, in 2005 dollars. 4 They report that attaining this standard would result in fewer premature deaths, fewer asthma atta cks, fewer cases of bronchitis, and fewer hospital admissions.

1 Peters, John, et al. (2004) Epidemiological Invest igation to Identify Chronic Effects of Ambient Air Pollutants in

Southern Californa . Conducted for the California Air Resources Board. University of Southern California, Los Angeles.

See http://www.arb.ca.gov/research/abstracts/94-331.htm

2 Jerrett, M. et al. (2009) Long-Term Ozone Exposure and Mortality . New England Journal of Medicine Vol. 360 (11):1085-1095. March 12.

3 Salam, M.T., J. Millstein, Y. Li, F. Lurmann, H. M argolis, and F. Gilliland. (2005) Birth Outcomes and Prenatal Exposure to Ozone, Carbon Monoxide, and Particulate Matter: Results from the Children’s Health Study

. Environmental Health Perspectives 113 (11): 1,638-1,644.

4 This estimate is based on a total of avoided hospi talization and related health care costs as well as the Value of a Statistical Life (VSL). The VSL is an economic est imate of the social value of premature death that i s used to guide policy makers in making public investments in publi c health or safety. VSL estimates range from $3.8 to $8.9 million per case. In the Hall et al. study, 67% of the $88 .9 million total was based on the VSL.4 SJVAPCD 2010 Ozone Mid-Course Review

In May 2009, District staff evaluated the economic cost savings attributable to implementation of the 2007 Ozone Plan through the year 2020. In 2020 dollars, the resulting cost savings to the San Joaquin Valley is $216,401,880. The analysis utilized the EPA’s Environmental Benefits Mapping and Analys is Program (BenMAP) to predict the avoided costs of respiratory emergency room vis its, respiratory hospital admissions, school days lost, acute respiratory symptoms, decre ased worker productivity, and premature mortality as a result of reductions in am bient ozone exposure resulting from implementation of the 2007 Ozone Plan

.

1.3 Mid-Course Review Summary This review presents an assessment at a basin-wide level of recent trends in emissions estimates with or without meteorological adjustment , monitored air quality data, and other corroborating analyses to demonstrate that the Dist rict’s and State’s strategies are resulting in emissions reductions and air quality i mprovement needed to attain the
revoked 1-hour ozone NAAQS and will result in the V alley’s attainment of the 1997 8- hour ozone NAAQS by or before the 2023 attainment d eadline. As a result of investments in cleaner technologies made by Valley businesses, municipalities, and residents, combined with emissions reductions imple mented at the state and local level for mobile sources, the Valley appears to be on-tra ck, in spite of anticipated population growth and an associated increase in vehicle miles traveled in the Valley.

To date, the District, through successful implement ation of the EOADP and 2007 Ozone

Plan , has achieved more emissions reductions than origi nally anticipated at the time of the respective plan approval because of aggressive and innovative regulatory, outreach and incentive efforts. Reaching attainment of the 8-hour ozone NAAQS will require continued aggressive efforts on all regulatory and non-regulatory fronts, including the development of new strategies to include the proact ive deployment of cleaner technologies and innovative control measures. To t his end, the District has funded several technology demonstration projects to assist in accelerating the widespread use of promising technologies.

Full attainment of the 1-hour ozone NAAQS by the at tainment deadline will require having no 1-hour ozone exceedances throughout the 2010 sum mer ozone season. I exceedances to occur, the District is prepared to i nitiate a Section 185 nonattainment fee program or alternative equivalent program to offset the federal requirement.Section 3 – Regulatory Control Measures 5 

## Section 2 - Air Quality & Regional Growth Trends

District staff conducted a number of analyses to de termine if the Valley is “on-track” to

achieve attainment of the 1-hour and 8-hour ozone N AAQS by their respective attainment deadlines. These analyses show that the District h as made considerable progress since the CAA was amended in 1990 toward significant redu ctions in ozone precursor

emissions and overall ozone concentrations. The de gree of progress is particularly noteworthy since significant emission reductions ha ve occurred despite concurrent population growth and an increase in vehicle miles traveled (VMT) within the Valley.

Despite significant regulatory and voluntary succes ses in the Valley, conditions and events outside of District control have a tendency to mask such successes in the shortterm. During the summer of 2008, California experi enced a high number of forest fires, which because of the concurrent meteorological cond itions, severely affected the air quality in the Valley. On June 25, 2008 there were over a dozen wildfires in forested areas, in addition to a grass fire burning over 800 acres. On the same day there was a ridge of high pressure bringing warm weather and st agnant air into the Valley, thus preventing dispersion of ozone and ozone precursors . There were at least ten other days

in the summer of 2008 that had similar wildfire and weather conditions. As seen in the following data, the effect of these conditions and events affect the annual averages and

decadal trends.

The results of such events are seen, to some degree throughout the Valley, in the number of exceedances, the ozone design values, and the Expected Peak Day Concentration values. In all cases, the 2008 data does not follow the existing trends represented by the previous reporting years, especi ally since 2004. In an effort to account for these events, ARB submitted Exceptional Event documentation to EPA on behalf of all California air districts requesting e xclusion of some of these exceedances from consideration in attainment determinations, bu t only for exceedances that resulted in multiple air districts. The District submitted Exc eptional Event documentation to EPA for exclusion of some exceedances caused by wildfires t hat predominantly affected the Valley and thus were not included in the ARB submit tal. EPA has yet to issue determinations on these requests.

2.1 Emission Trends The District and California (State), following EPA guidelines, have implemented numerous ozone reduction strategies since 1990, res ulting in significant reductions in both volatile organic compounds (VOC) and oxides of nitrogen (NOx) emissions. These reductions will continue to grow through 2012 and b eyond. Figures 2-1 and 2-2 show that anthropogenic VOC and NOx emissions are expect ed to decline by 43 percent and 41 percent, respectively, by 2012 from 1990 emissio n projections. Figures 2-1 and 2-2 illustrate the reductions from each source category : area sources, or those not large enough to be tracked individually, such as a househ old water heater; stationary sources, or those that are not mobile, but large enough to b e tracked individually, such as a power plant; on-road mobile sources, or those that operat e predominantly on roads such as automobiles; and “mobile other,” or those mobile so urces that are not operated on roads,

such as boats.6 SJVAPCD 2010 Ozone Mid-Course Review 187 141 216 75

89

148 135 70

81

155 63 51

0 100 200 300 400 500 600 700Emissions (Annual Average tons/day)

1990 1999 2012 Figure 2-1 Valley VOC Planning Emission Projection s

Stationary Area On-Road Mobile Other

269 20 344 214

139

19 335 181

101

18 258 119

0 100 200 300 400 500 600 700 800 900Emissions (Annual Average tons/day)

1990 1999 2012 Figure 2-2 Valley NOx Planning Emission Projection s

Stationary Area On-Road Mobile Other

Additional strategies at the District and State lev el will provide substantial further emissions reductions after 2010. For example, on-r oad control strategies are projected to provide additional VOC and NOx reductions of 22 percent and 26 percent, respectively, from that source sector between 2010 and 2014, even after consideration of expected growth in vehicle miles traveled. While t hese projections are based on the current statewide mobile source rules, ARB is consi dering revisions to the private-fleet  43 %

 21 %

 41 %

 27 %Section 3 – Regulatory Control Measures 7

truck rule and off-road construction equipment rule in 2010. In light of the current economic downturn, including reduced activity in th e trucking and construction industries and associated reduced emissions statewide, ARB is considering an extended compliance timeline for both of these mobile-source rules. While such amendments are expected to delay emissions reductions previously s cheduled for 2010 through 2011 until 2012, there will be no effect on the reductions ult imately projected for 2014. Such relaxation of compliance timelines will also give m uch needed relief to two industries that are severely affected by the current economic condi tion, while acknowledging reductions resulting from decreased equipment use during the e conomic downturn.

2.2 Air Quality Trends The current ozone monitoring network consists of th e 22 sites mapped in Figure 2-3. This monitoring network is jointly maintained by th e District, ARB, and the National Forest

Service.

Figure 2-3 Air Monitoring Network in the San Joaqu in Valley

Ozone levels over the period of record have improve d dramatically, corresponding to the significant decrease in ozone precursor emissions d iscussed above. The decrease in



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Arvin Edison

Lebec Maricopa Oildale

Planz Road CA Avenue Porterville Ash Mountain Kaweah

Shafter Corcoran Visalia – Church St. Visalia Airport

Hanford Huron Santa Rosa Rancheria Tranquillity Hazelton Wagner/Holt

Tracy Modesto

Turlock Merced-M St.

Merced- Coffee

Madera City

Madera Clovis

Parlier

Drummond Fresno-Pacific

Sierra Sky Park First Street

San Joaquin

Stanislaus

Merced Madera

Fresno

Kings Tulare

Kern (SJV)8 SJVAPCD 2010 Ozone Mid-Course Review

ozone levels is shown in Figure 2-4, which shows a decline from 1999 through 2009 in the annual frequency of days exceeding the 1-hour a nd 8-hour ozone standards. Ozone

trends are examined in more detail in the remainder of this section.

Figure 2-4 Valley Annual Exceedance Days

117

103 109 125 134

109

72 86

65 66

28 30 32 31 37

9 8 18

3 3 82*

19*

0 20 40 60 80 100 120 140 160

1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009

Year# Exceedance Days

8-hr Ozone 1-hr Ozone

* 2008 impacted by wildfires.

2.2.1 Ozone Design Values Compliance with the 1-hour and 8-hour ozone NAAQS i s achieved when the highest design value for all monitors in an area does not e xceed 125 and 85 parts per billion (ppb), respectively. For the 1-hour ozone NAAQS, t he design value at each monitor site

is defined as the 4 th highest daily maximum ozone concentration measured over a 3-year calendar period. Whereas, for the current 8-hour o zone NAAQS, the design value at each monitor site is defined as the average of each year’s 4 th highest value for three consecutive years.

Design values for 1-hour ozone and 8-hour ozone are plotted in Figure 2-5 and Figure 2- 6, respectively. For each plot, the calculated des ign value is designated as a data point for each respective year. The maximum 1-hour ozone design values decreased from 161 parts per billion (ppb) in 1999 to 136 ppb in 2008, which represents a 16 percent decrease. The average maximum 8-hour design values have also decreased over the same time interval by 4 percent. In both plots, th e trend of design values data points was extrapolated by applying a best-fit line to the dat a, which is represented in Figure 2-5 and Figure 2-6 as a solid black line.

The interval of normal meteorological fluctuation i s represented as the residual, or difference between the expected value and the obser ved value. This difference is “added to” or “subtracted from” the trend line to represen t the upper and lower residual, respectively, and is represented by the thinner das hed lines parallel to the trend line in Figure 2-5 and Figure 2.6. These residual lines re present the maximum and minimum design values for a year after considering meteorol ogical fluctuations. The preliminarySection 3 – Regulatory Control Measures 9

2009 1-hr ozone design value falls within these bou ndaries, while the preliminary 8-hour ozone design value falls well below even the lower residual line, further supporting the downward trend of improved ambient air quality.

These findings, however, do not take into account t he higher-than-anticipated ozone values recorded in 2008 as a result of exceptional events and unfavorable meteorology. Since the latest three years of data is evaluated t o determine attainment of the standard, if the District does not receive approval for the E xceptional Events in 2008, it may not be

feasible to demonstrate attainment in 2010. In suc h case, the District would submit and Attainment Demonstration Extension request to EPA f or 2010, which would extend the
attainment deadline for the 1-hour ozone NAAQS from 2010 to 2011. Such a finding would acknowledge the general downward trend shown in Figure 2-5, thus recognizing the fact that 2008 was an atypical year with regard to summertime ozone levels.

Figure 2-5 Trends of Maximum 1-hr Ozone Design Valu e (DV)

y = -2.8364x + 163.2 y = -4.4x + 176.4

125 130 135 140 145 150 155 160 165

1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009

Year1-hr Ozone Design Value (ppb)

1-hr DV Upper Residual Lower Residual

Prelim 2009 DV 2004-2008 Trend (2004-2008) * Residual is the difference between the expected v alue and the observed value.

Of important consideration is the significant decre ase in ozone design values measured from 2004 to 2008. This increased rate of change c oincides with implementation of the

EOADP and 2007 Ozone Plan , both of which have resulted in significant emissi ons reductions over the last four years.10 SJVAPCD 2010 Ozone Mid-Course Review Figure 2-6 Trends of Maximum 8-hr Ozone Design Val ue (DV)

y = -0.4424x + 114.13

y = -2.2x + 128.4

104 106 108 110 112 114 116 118 120

1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009

Year8-hr Ozone Design Value (ppb)

8-hr DV Upper Residual Lower Residual

Prelim 2009 DV 2004-2008 Linear (2004-2008) * Residual is the difference between the expected v alue and the observed value.

As the District continues the aggressive implementa tion of regulatory control measures in

the 2007 Ozone Plan

and utilizes more innovative strategies to realize non-regulatory emissions reductions, it is reasonable to predict t hat the accelerated rate of improvement will continue on the same, if not steeper, trend as the previous four years.

Looking at the data in this regard and given the de sign value trends between 2004 and 2008, attaining the appropriate design values by th e attainment deadline is possible, yet will require aggressive implementation of voluntary programs and regulatory controls to further reduce emissions. Using the 2004 through 2 008 trend line, as indicated by the heavy dashed trend line in Figure 2-6, the 8-hour d esign value of 85 ppb is realized by 2019, four years prior to the attainment deadline.

2.2.2 Ozone Exceedance Days While the design value limit determines the occurre nce of an exceedance day, it is the actual number of exceedance days within a three-yea r period at a given monitoring site
that determines attainment of the ozone NAAQS. An exceedance day is defined as a day, measured from midnight to midnight, in which o ne or more monitors in the Valley records a concentration above the applicable NAAQS for ozone. The total number of days within the Valley in which an exceedance was r ecorded as measured for 1-hour and 8-hour ozone for each year from 1999 through 2009 w as displayed previously in Figure 2-4. That analysis shows that the number of 1-hour exceedance days has decreased since 1999 by 90 percent from 28 days to 3 days in 2009. Likewise, the number of 8- hour exceedance days has decreased by 44 percent fr om 117 to 66 for the same period

of record.Section 3 – Regulatory Control Measures 11

Valley ozone attainment designations for the 1-hour and 8-hour NAAQS require meeting attainment by 2010 and 2023, respectively, and subm itting a Clean Data Finding for the three years prior to attainment. If the District w ere to receive a one- to two-year extension, the requirement for making the Clean Dat a Finding would also be delayed by the same time period. Once a Clean Data Finding is approved by EPA, all planning requirements for ozone are suspended, including sub sequent attainment demonstrations and rate-of-progress plans

Figure 2-7 represents exceedance days in the Valley since 1999 and includes a best-fit linear trend of the data through 2023. Assuming th e downward trends continue at the same rate, projected 8-hour ozone exceedances would be eliminated prior to the 2023 attainment deadline. The slope of the trend lines are dependant on the years selected to develop them, 10 years in this case, but the future frequency of exceedance days will be affected more significantly by implementation of in novative strategies, new clean-air technology made available for industrial use, and m eteorological conditions. The trend lines, shown in heavy solid and dashed lines in Fig ure 2-7, indicate that compliance with the 8-hour ozone NAAQS is achievable prior to the 2 023 attainment deadline.

Figure 2-7 Trends in Valley Exceedance Days

y = -2.8273x + 36.782 y = -5.5545x + 130.42

0 20 40 60 80 100 120 140 1601999200020012002200320042005200620072008200920102011201220132014201520162017201820192020202120222023

Year# Exceedance Days

8-hr Ozone 1-hr Ozone 1-hr Ozone Trend 8-hr Ozone Trend

While the simple 1-hour ozone trend line indicates that the number of exceedances will reach zero by 2012, attainment of a NAAQS is reache d when there are no more than three exceedances within a three-year period. Whil e there were three exceedances in 2009, there were 19 exceedances in 2008, most of wh ich were caused by wildfire

emissions. 5 The earliest attainment date would be December 31 , 2011, only if no 1-hour

ozone exceedances occurred in 2010 or 2011. In thi s case, the District would request an

5 The higher than expected number of exceedances sho wn in 2008 is likely attributable to an unusually h igh frequency of wildfires that occurred during June and July of 2008 in Central Ca lifornia. In addition to particulate matter and ca rbon monoxide, wildfires release significant NOx and hydrocarbons creating excessive ground-level ozone even in areas far away from tra ditional urban ozone sources. ARB submitted Exceptional Event documenta tion to EPA on behalf of all California air distric ts requesting exclusion of some

of these exceedances from consideration in attainme nt determinations.12 SJVAPCD 2010 Ozone Mid-Course Review

extension to 2011 from EPA. In 2012 the District w ould be able to request that EPA make a Clean Data Finding based on 2009 through 201 1 data.

As regulatory control measures and innovative strat egies continue to lower Valley ozone levels, meteorology and wildfires have a proportion ately more significant effect on

measured ozone levels and the number of exceedance days. In other words, despite the fact that significant progress has been made, as sh own in the reductions of ozone and ozone precursor emissions, the meteorology and wild fires may create a stronger possibility for the occurrence of a 1-hour ozone ex ceedance. Given the potential for 1-

hour ozone exceedances over the next two summer ozo ne seasons, the District is prepared to implement a Section 185 nonattainment f ee program, or implement an alternative equivalent program to offset fees impos ed by the federal requirement, if required.

2.2.3 8-hr Ozone Expected Peak Day Concentration (E PDC) The Expected Peak Day Concentration (EPDC) is usefu l for tracking ambient air quality progress at individual monitoring locations. The E PDC is calculated for each monitor location using daily maximum 8-hour ozone observati ons for a three-year period, which includes the summary year and the two years immedia tely prior to the summary year. The EPDC is computed using a statistical procedure that fits an exponential-tail model to the upper tail of the distribution of concentration s. The fitted distribution is used to analytically determine the peak concentration expec ted to occur once per year, on average. This robust statistical calculation is re latively stable and provides a trend indicator that is not highly influenced by year-to- year changes in meteorology.

Figure 2-8 details the EPDC data made available by ARB for each monitoring station within each county of the Valley. For the years 19 94 to 2008, the data indicates that the counties of San Joaquin, Stanislaus, Fresno, Tulare , and Kern have experienced a downward trend in EPDC. Similarly, but for shorter periods of data collection, the counties of Madera and Kings are also seeing a lowe ring of EPDC values 6 . In all counties except San Joaquin and Kings, the year 200 8 does not fall along the downward trend line. As indicated previously, in 2008 the V alley was affected by an unusually large number of wildfires that plagued the state of Calif ornia together with a significant number of days in which inversion layers or other meteorol ogical conditions prevented pollutant dispersion.

The steady improvement in EPDC values in part repre sents regulatory and nonregulatory efforts to reduce emissions of ozone pre cursors. As with the design value data shown previously in this section, the EPDC dat a from the counties of Madera, Fresno, Tulare, Kings, and Kern all show marked imp rovements in EPDC values starting in the year 2004, which coincides with the implemen tation of the District’s strategies to

attain the federal health standard for the 1-hour o zone NAAQS and implementation of the

EOADP . Continued improvement coincides with implementat ion of control measures

identified in the 2007 Ozone Plan , which to date have provided more emissions reductions than was committed to at the time of pla n adoption.

6 Merced County is not included in the EPDC analysis because of the lack of valid data for the years 20 06 through

2008.Section 3 – Regulatory Control Measures 13 Figure 2

- 8 Valley Expected Peak Day Concentration (EPDC)

Stanislaus County

y = -0.0008x + 0.1129

0.08 0.09 0.1 0.11 0.12 0.13 0.14

1994 1996 1998 2000 2002 2004 2006 2008

Modest o-14t h

St reet Turlock-S Minaret St reet

Fresno County

0.08 0.09 0.1 0.11 0.12 0.13 0.14

1994 1996 1998 2000 2002 2004 2006 2008

Kings County

0.08 0.09 0.1 0.11 0.12 0.13 0.14

1994 1996 1998 2000 2002 2004 2006 2008

Summary Year Hanf ord-S Irwin St reet Madera County

0.08 0.09 0.1 0.11 0.12 0.13 0.14

1994 1996 1998 2000 2002 2004 2006 2008ppm Madera-Pump Yard

Tulare County

y = -0.0016x + 0.1249

0.08 0.09 0.1 0.11 0.12 0.13 0.14

1994 1996 1998 2000 2002 2004 2006 2008ppm Visalia-N Church St .

Kern County

0.08 0.09 0.1 0.11 0.12 0.13 0.14

1994 1996 1998 2000 2002 2004 2006 2008

Summary Yearppm San Joaquin County

0.08 0.09 0.1 0.11 0.12 0.13 0.14

1994 1996 1998 2000 2002 2004 2006 2008ppm

St ockt on-Hazelt on St reet

1-Fresno-1st St

2-Parlier

3-Fresno-Sierra Skypark # 2

4-Clovis-N Villa Ave

5-Fresno-Drummond St

1-Edison

2-Arvin-Bear M ountain Blvd

3-Bakersfield-5558 California Ave
4-M aricopa-Stanislaus St
5-Bakersfield-Golden State Hwy

6-Oildale-3311 M anor St

7-Shafter-Walker St14 SJVAPCD 2010 Ozone Mid-Course Review

2.3 Evaluation of Ozone Trends Adjusted for Weather Analysis to this point has relied on direct observa tions of ozone. However, since ozone concentrations are highly dependent on weather cond itions, long-term weather patterns, such as shorter than average winter seasons and dry er than normal winters, make interpretation of ozone trends challenging. The ch anging distribution of weather parameters, such as temperature, wind, ultraviolet radiation, and vertical stability, result in seasons with greater or lesser potentials to pro duce ozone than an “average” season. Without considering the effect of meteorology on oz one concentrations, it is difficult to determine if changes in observed ozone concentratio ns are due to effective control strategies or meteorological fluctuations.

District analysis indicates that long-term fluctuat ions in weather patterns create significant variation in annual season-average ozone concentrat ions. These large variations in seasonal ozone averages attributed to weather indic ate that caution should be used when evaluating ozone observations not adjusted for weather. However, during the past decade 1-hour and 8-hour average meteorologically-a djusted ozone concentrations have steadily decreased, indicating that the observed lo ng-term ozone improvement trend is likely attributable to emission reductions and not weather variations. Further analysis indicates that the overall weather-adjusted ozone t rend is nearly identical to, but decreases slightly faster than, the overall unadjus ted trend. This finding indicates that ozone trend analysis completed throughout this repo rt is valid and potentially

conservative. The remainder of this section descri bes the process and results in further

detail.

2.3.1 Meteorological Adjusted Ozone Trend Methodolo gy EPA developed a statistical method to account for t he weather-related variability of

seasonal ozone concentrations 7 . This method compares the observed seasonal avera ge daily 1-hour and 8-hour average ozone concentration s to the same parameters with the

influence of weather removed. Since this method us es seasonal average concentrations, results cannot be directly compared to ambient air quality standards, which are based on daily 1-hour and 8-hour concentrations. However, t he method is an excellent choice for evaluating the overall influence of weather on the entire ozone season.

To assess the underlying trends in ozone, the Distr ict first selected meteorological parameters most influential over San Joaquin Valley ozone concentrations. These selected parameters, including, but not limited to, maximum temperature, standard temperature, wind speed, vertical stability, and so lar radiation, were used to develop quantitative relationships between ozone and meteor ology for monitoring sites in the Valley. Results from this quantitative relationshi p were compared against observed air quality. The weather-adjusted ozone trend can be u sed to evaluate changes in precursor

emissions attributable to control measures. The si tes chosen for this analysis were generally those that show the highest average ozone concentrations, or the “dirtiest,” the exception being Merced, which was chosen as a repre sentative site for the north Valley.

7 Camalier, L., Cox, W., Dolwick, P. (2007) The Effects of Meteorology on Ozone in Urban Areas and Their Use in Assessing Ozone Trends . Atmospheric Environment 41: 7127-7137.Section 3 – Regulatory Control Measures 15

2.3.2 Meteorological Adjusted Ozone Trend Interpret ation Figures 2-9 through 2-22 show the seasonal average daily 1-hour ozone concentrations for the summer months of May through September from 1999 through 2009. The narrower dotted line with hollow data points shows season average observed concentrations at monitoring sites, while the solid black line with solid data points shows season average weather-adjusted concentrations. The weather-adjusted values create a representation of seasonal average ozone concentrat ions anticipated under typical

weather conditions and serves as a more accurate me thod for evaluating ozone trends associated with emission changes. The heavy dashed line and the heavy solid line show the linear trend in season average concentrations a nd weather-adjusted concentrations, respectively.

When the unadjusted value is greater than the meteo rologically adjusted value, the seasonally averaged observed concentrations were hi gher due to weather. When the unadjusted value line is less than the meteorologic ally adjusted value, the seasonally averaged observed concentrations were lower due to weather. When the adjusted value closely approximates the unadjusted value, the summ er was near the statistical average.

Figures 2-9 through 2-22 indicate that the summer o f 2002 was near the statistical average for most sites, since observations are clos ely approximated by adjustments for weather. In addition, the significant increase in o zone concentrations from 2000 to 2003, was largely due to the influence of weather, as is evident from the generally flat trend in ozone concentrations adjusted for weather at most s ites. In addition, although much of

the 2008 summer observations are attributable to we ather, increases in ozone concentrations adjusted for weather can be attribut ed to the influence of northern and central California wildfire emissions during the 20 08 ozone season.

After being adjusted for weather, all sites evaluat ed (Figures 2-9 through 2-22) show a decrease in 1-hr and 8-hr average ozone concentrati ons from 1997 to 2009. Since this trend is decreasing, rather than flat or increasing , it indicates that emissions reductions, not weather, were responsible for observed ozone im provements. In addition, since the overall weather-adjusted ozone trend is nearly iden tical to, but slightly steeper than, the overall unadjusted trend, analysis completed throug hout this report is valid and potentially

conservative.16 SJVAPCD 2010 Ozone Mid-Course Review

Figure 2-9: Arvin, 1-hr Ozone Trends

Figure 2-10: Edison, 1-hr Ozone TrendsSection 3 – Regulatory Control Measures 17

Figure 2-11: Fresno-First St, 1-hr Ozone Trends

Figure 2-12: Fresno-Sierra Sky Park, 1-hr Ozone Tre nds18 SJVAPCD 2010 Ozone Mid-Course Review

Figure 2-13: Clovis, 1-hr Ozone Trends

Figure 2-14: Parlier, 1-hr Ozone TrendsSection 3 – Regulatory Control Measures 19

Figure 2-15: Merced-Coffee, 1-hr Ozone Trends

Figure 2-16: Arvin, 8-hr Ozone Trends20 SJVAPCD 2010 Ozone Mid-Course Review

Figure 2-17: Edison, 8-hr Ozone Trends

Figure 2-18: Fresno-First St, 8-hr Ozone TrendsSection 3 – Regulatory Control Measures 21

Figure 2-19: Fresno-Sierra Sky Park, 8-hr Ozone Tre nds

Figure 2-20: Clovis, 8-hr Ozone Trends22 SJVAPCD 2010 Ozone Mid-Course Review

Figure 2-21: Parlier, 8-hr Ozone Trends

Figure 2-22: Merced-Coffee, 8-hr Ozone TrendsSection 3 – Regulatory Control Measures 23

2.4 Growth Trends in Population & Vehicle Miles Tra veled The significant decline in emissions and ozone leve ls over the past several decades has occurred during a period of overall population grow th and increased vehicle miles traveled (VMT) in California and the Valley.

As shown in Figure 2-23, population in the Valley h as increased by 26 percent since 1999, whereas the population in the State only incr eased 16 percent over the same 10- year period. While the projected population growth from 2010 through 2020 is expected to be only 13 percent, the Valley is projected to s ee a 26 percent increase for the same time period.

Figure 2-23 Estimated Population Growth

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%19992001200320052007200920112013201520172019Growth Relative to 1999

CA Valley

Source: ARB CEPAM:2009 Almanac – Population and Veh icle Trends Tool

A similar trend holds true for VMT in California an d the Valley. From 1999 to present, VMT in California has increased 20 percent; however the Valley has seen a 32 percent increase in VMT. For the 10-year period between 20 10 and 2020, the projected VMT increase for California is 15 percent and 25 percen t for the Valley.

Figure 2-24 Estimated Growth in Vehicle Miles Trave led

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%19992001200320052007200920112013201520172019Growth Relative to 1999

CA Valley

Source: ARB CEPAM:2009 Almanac – Population and Veh icle Trends Tool24 SJVAPCD 2010 Ozone Mid-Course Review

Based on the growth in population and the associate d increase in VMT, one would expect a related significant percent increase in oz one. However, as shown throughout this review, there has been a significant decrease, suggesting that control strategies have both mitigated the increase in ozone attributable t o population growth and decreased the

baseline ozone levels.

2.5 Summary of Air Quality and Regional Growth Tren ds Consistent with the strategies identified in the EOADP and 2007 Ozone Plan, the District has implemented regulatory control measures and non -regulatory, voluntary programs that have significantly affected the ozone and ozon e precursor concentrations, as shown in the above data and analyses. As detailed in the above analysis, the District is on-track

to reach attainment of the 1-hour and 8-hour ozone NAAQS despite increases in population and VMT. The District will continue to implement all feasible controls and innovative strategies, and aggressively pursue gran t funding to accelerate attainment.Section 3 – Regulatory Control Measures 25 

## Section 3 - Regulatory Control Measures

Traditionally, the District’s primary means to meet the challenges of air quality in the Valley are its regulatory stationary source control measures. The District’s 1-hour and 8- hour ozone plans, EOADP and 2007 Ozone Plan , respectively, identified such regulatory control measures. At full implementation of the EOADP, and for the implementation-todate of the 2007 Ozone Plan , the District has achieved more emissions reductio ns of ozone precursor emissions than was committed to at the time of each plan’s adoption. This is consistent with the improving air quality t rends shown previously in Section 2. These reductions are in addition to those generated by District incentive programs, innovative programs, and state, federal, and local measures, as presented in this review.

3.1 Implementation of Stationary Source Regulatory Controls Tables 3-1 lists the stationary source rules adopte d or amended consistent with EOADP. The District adopted these rules or rule amendments from 2005 through 2007 with full implementation anticipated by 2010. For both ozone precursors, the adopted rules

achieved more emissions reductions than were commit ted to in the EOADP. Rule 9510, Indirect Source Review, is discussed more fully in Section 4.

Once EPA approved the EOADP , the inventories and assumptions in the SIP became the legal benchmark or baseline for calculating future emissions reductions beyond that point. Since during the rule development process n ew information is obtained regarding the emission inventory, the rule baseline, or inven tory, may be different from the plan baseline or inventory. The reductions calculated d uring the rule development process are calculated base on the rule baseline. Thus, ev aluation of rule effectiveness with regard to emissions reductions requires the convers ion of the rule reductions to “SIP Currency.” All reductions in Tables 3-1 and 3-2 ar e stated in SIP Currency and are

calculated as follows:

Baseline Plan Currancy SIP in Reductions Emission Baseline Rule Reductions Rule

× =26 SJVAPCD 2010 Ozone Mid-Course Review Table 3-1 Completed 1-hour Ozone Plan Control Meas ures

Plan

Commitment (tons/day) Actual

Reductions (tons/day) Additional

Reductions (tons/day) Control Measure Rule

# Completion Reductions

Start *

NOx VOC NOx VOC NOx VOC

Open Burning (Phase 3) 4103 2007 2007 2.3 2.9 2.8 3 .9 0.5 1.0 Oil and Gas Fugitives 4409 2005 2005 0 4.7 0 4.5 0 -0.2 Refinery & Chemical Fugitives 4455 2005 2005 0 0.2 0 0.4 0 0.2

Wineries - Fermentation and Storage 4694 2005 2007 0 0.7 0 0.7 0 0

Composting/Biosolid Operations 4565 2007 2008 0 0.1 0 0.3 0 0.2

Automotive Coating 4602 2006 0 0.1 0 0.6 0 0.5

Concentrated Animal Feeding Operations 4570 2006 2006 0 15.8 0 22.8 0 7.0

Organic Solvent Degreasing 4662 Organic Solvent Cleaning 4663

Motor Vehicle and Mobile Equipment Coating 4602

Surface Coating of Metal

Parts and Products 4603

Can and Coil Coating Operations 4604

Aerospace Assemblies and Component Coating 4605

Wood Products Coating 4606
Graphic Arts 4607

Adhesives 4653
Polyester Resin Operations 4684 2007 2009 0 1.3 0 3.1 0 1.8

Steam-Enhance Oil Well

Vents 4401 2006 2007 0 1.4 0 1.2 0 -0.2

Soil Decontamination 4651 2007 2008 0 0.1 0 0.1 0 0
Polymeric Foam Manufacturing 4682 2007 2007 0 0.1 0 0.4 0 0.3

Gasoline Storage &

Transfer 4621

4624 2007 2009 0 1.0 0 2.1 0 1.1

School Bus Fleet Rule 9310 2006 2010 2.6 0 4.0 0 1. 4 0
Small Boilers, Process Heater, Steam Generators,

2.0-5.0 Mmbtu/hr 4307 2005 2006 9.0 0 13.1 0 4.1 0

Solid-Fuel Boilers, Steam Generators, & Process

Heaters 4352 2006 2007 4.4 0 4.3 0 -0.1 0

Stationary IC Engines 4702 2005 2006 20.1 0 28.7 0 8.6 0

Water Heaters 0.075-

2.0MMBtu/hr 4308 2005 2008 1.4 0 2.0 0 0.6 0

Stationary Gas Turbines 4703 2007 2009 2.5 0 3.0 0 0.5 0

Completed Control Measures Totals 42.3 28.4 57.9 40 .1 15.8 11.7

* All emission values are for calendar year 2014 an d controls, in tons per day, rounded to the nearest then of a ton per daySection 3 – Regulatory Control Measures 27

Likewise, Table 3-2 lists the completed stationary source control measures along with the original 2007 Ozone Plan commitments for the emissions reductions, the esti mated emission reductions based on the adopted rule, and any emission reductions that were surplus to the plan commitments. The District adop ted the measures according to the

schedule identified in the 2007 Ozone Plan . Most of the control measures are expected to be fully implemented by 2017, with the majority of the emissions occurring before

2015. Emission reductions shown in Table 3-2 are b ased on 2014 inventories and

controls.

The emission reductions estimates in 2007 Ozone Plan were based on control techniques existing at the time the Plan was develo ped. During rule development, the District sometimes found that technologies had adva nced and that new more-effective control techniques were available for each measure. These more-effective control techniques were considered in each rule development project and resulted in increased

emission reductions from the 2007 Ozone Plan commitments. In some cases, however, it was determined that previously considered contro l technology was not applicable to the entire source category and fewer reductions were re alized from some of the control measure projects. In 2014, the currently adopted c ontrol measures will produce an additional 8.0 tons per day of NOx and 3.2 tons per day of VOC, compared to the 2007

Ozone Plan

commitments. The additional emission reductions w ill be used to offset any shortfalls that may occur in future rule developmen t projects and will be applied towards the additional “Black Box” reductions required by t he 2007 Ozone Plan

.28 SJVAPCD 2010 Ozone Mid-Course Review

3.2 Feasibility Studies

In addition to the 2007 Ozone Plan regulatory commitments, the District has pursued, and continues to pursue, a number of feasibility st udies for potential control measures to evaluate opportunities for additional emissions red uctions. The studies listed in Tables 3-

3 and 3-4 were identified in the 2007 Ozone Plan because there was not sufficient information available to determine the feasibility or effectiveness of these potential control measures at the time of plan adoption. Not all of the studies listed in Tables 3-3 and 3-4 will produce a viable rule project, incentive progr am, or advocacy action; in some cases, the emissions inventory may prove to be too small o r the affected sources may not lend themselves to additional control technology or best management practices. The goals of the feasibility study process are to: 1) determine whether or not actions to reduce emissions are technically and economical feasible f or the potential control measure; and 2) provide closure on the plan commitment, in other words to proceed with rulemaking, advocacy commitment, incentive program, or other co mmitment, or make a final determination of non-feasibility.

During the feasibility study process, as required, necessary, and appropriate, staff

considers:

• Updating the emission inventories for the sources t o be considered in the feasibility study;

Table 3-2 Completed 2007 Ozone Plan Control Measures

Plan

Commitment (tons/day) Actual

Reductions (tons/day) Additional

Reductions (tons/day) CM# Control Measure Rule

# Completion Reduction

Start

NOx VOC NOx VOC NOx VOC

S-GOV-1 Composting – Bio-solids 4565 2007 2008 0 3.9 0 3.9 0 0
S-AGR-1 Open Burning, Phase III & IV 4103 2007 2007 2.4 2.8 2.4 2.8 0 0

S-SOL-11 Solvents 4661

4662

4663 2007 2010 0 1.4 0 3.3 0 1.9

S-COM-5 Gas Turbines 4703 2007 2010 0.6 0 2.2 0 1.6 0

S-IND-24 Soil Decontamination 4651 2007 NA 0 0 0 0 0 0
S-IND-6 Polystyrene Foam 4682 2007 2011 0 0.1 0 0.4 0 0.3

S-PET-1,2

S-PET-3 Gasoline Storage & Transfer

Aviation Fuel Storage 4624

4623 2007 2009 0 1.2 0 1.4 0 0.2

S-COM-1 Large Boilers 4306

4320 2008 2011 0.7 0 3.3 0 2.6 0

S-COM-2 Medium Boilers 4307 2008 2012 0.5 0 5.1 0 4.6 0
S-COM-7 Glass Melting Furnaces 4354 2008 2008 1.7 0 0 0 -1.7 0
S-SOL-20 Graphic Arts 4607 2008 2011 0 0.1 0 0.1 0 0

S-COM-9 Residential Water Heaters 4902 2009 2011 0.4 0 0.5 0 0.1 0

S-IND-21 Flares 4311 2009 NA 0 0 0 0 0 0
S-IND-14 Brandy & Wine Aging 4695 2009 2012 0 0 0 0 0 0
S-SOL-1 Architectural Coatings 4601 2009 2012 0 2.1 0 3 0 0.9

S-COM-3 Small Boilers* 4308 2009 2011 0 0 0.6 0 0.6 0
M-TRAN-1 Employer-Based Trip Reductions 9410 2009 2014 0.3 0.6 0.5 0.5 0.2 -0.1

Completed Control Measures Totals 6.6 12.2 14.6 15.4 8.0 3.2

Note: All emission values are for calendar year 2014 emis sions and controls, in tons per day, rounded to the nearest tenth of a ton per day. All values in SIP Currency. * Feasibility Study commitment in 2007 Ozone Plan . Feasibility Study completed in 2009 with subsequ ent rulemaking. No Plan

control measure commitment.Section 3 – Regulatory Control Measures 29 • Reviewing best management practices and technologie s that likely have the potential to achieve cost-effective emission reduct ions from the sources considered by the feasibility study;

• Reviewing regulatory, incentive, and advocacy optio ns for achieving emission reductions from the sources being evaluated by the feasibility study;

• Providing details to the public of the District’s i ntended actions for this source category based on information acquired by staff dur ing the feasibility process. This may be at a rule development workshop, stakeho lder workshop, in a document or notice published on the internet, or th rough any other means deemed appropriate by staff considering the applica bility and results of the feasibility study.

District staff may also research other controls mea sures that are not identified in an adopted attainment plan, but which are suggested af ter the plan is finalized. These studies may include application of reasonably avail able control technology or management practices for current or new sources whe re emission reductions are costeffective via a rule, incentive program, or other s trategy. As with every rule development process, the new or amended rule will be developed according to the District’s normal procedure of public involvement to gather ideas, co st data, economic impacts, and other feedback on the draft rule prior to seeking Governi ng Board approval of a proposed rule. Continued awareness of additional measures, such as those that may be identified in the feasibility study process, are needed to achieve th e additional reductions required by the

2007 Ozone Plan

“black box.” Specifically the “black box” require s that regulatory or nonregulatory measures shall be put in place by the en d of 2019 that account for 82 tpd of NOx emissions reductions, to be achieved by the end of 2023.

Since the 2007 Ozone Plan was adopted, the District has completed or initiat ed all feasibility studies that were scheduled by 2009. T he following subsections briefly describe the completed or initiated control measure feasibility studies, as summarized in

Table 3-3.

Table 3-3 Initiated or Completed Stationary Source Feasibility Study Projects

Control

Measure # Control Measure Name Completion

Date Outcome

S-COM-6 Internal Combustion Engine (ICE)

Electrification/Pump Efficiency Incentives In Progress Pending further emission inventory

refinement

S-GOV-6 Prescribed Burning 2008 Increase Legislative advocacy, public education, interagency coordination

Program Review Open Burning Biomass Incentive 2008 Incentive Program Potential, Funding

not Identified

S-PET-13 Crude Oil Production Sumps In Progress Pending further evaluation and inventory

refinement

S-PET-16 Heavy Crude Oil Components 2009 Not cost effective for additional VOC

controls

S-COM-4 Solid Fuel Fired Boilers 2009 Recommended for Rulemaking

S-COM-3 Small Boilers 2009 Recommended for Rulemaking

Shading represents completed Feasibility Studies30 SJVAPCD 2010 Ozone Mid-Course Review Table 3-4 Planned Stationary Source Feasibility St udy Projects

Control

Measure # Control Measure Name Anticipated Completion Date

S-IND-12 Wine Fermentation & Storage 2010

S-IND-5 Asphalt Roofing 2010

S-PET-18 Heavy Oil Testing Stations (HOTS) & Gauge Tanks 2010

S-AGR-4 Pesticide Fumigation Chambers 2011

S-COM-11 Dryers 2011

S-GOV-4 Asphalt Paving 2011

S-IND-13 Bakeries 2011

S-COM-6 ICE – Standards Review 2012

S-GOV-2 Municipal Water Treatment Plants (POTW) 20 12

S-IND-23 Reduction of Animal Matter 2012

S-PET-22 Refinery Turnaround Units 2012

S-PET-23 Refinery Vacuum Devices 2012

S-PET-24 Refinery Wastewater Separators 2012

3.2.1 Internal Combustion Engine (ICE) Electrificat ion/Pump Efficiency Incentives

The 2007 Ozone Plan

committed the District to conduct a feasibility st udy for emissions reductions from expanding regulation of incentive p rograms for Reciprocating Internal Combustion Engines (ICE). Businesses and agencies that use internal combustion engines include, but are not limited to, schools an d universities, dairies, agricultural production, petroleum refiners, food processing, pu blic water districts, and manufacturing. Many compression-ignited engines are used in agricu ltural production for irrigation and in other businesses as emergency engines to provide ba ckup power when electric service is interrupted.

District staff evaluated rules from other air distr icts, including South Coast Air Quality Management District, and the BACT database to ident ify potential options. Staff reviewed the District permit and grant databases to estimate the number of reciprocating internal combustion engines over 50 horsepower oper ating in the Valley and sorted these by fuel type (diesel, natural gas, or electric). S taff then met with agricultural industry stakeholders to solicit input of the feasibility of ICE electrification and pump efficiency

incentives.

Preliminary indications as to the feasibility of ob taining cost-effective emissions reductions from this source category are good. Add itionally, many agricultural industry stakeholders including the California Cotton Ginner s and Growers Association supported the concept of increased use of incentive to assist growers in the effort to address engine emissions. Industry also supported implementation of pump efficiency programs, where applicable, if these programs were implemented on a voluntary basis. District staff is in the process of obtaining additional inventory infor mation regarding this source category. Completion is anticipated in 2010.Section 3 – Regulatory Control Measures 31

3.2.2 Prescribed Burning

In the 2007 Ozone Plan , the District committed to conducting a feasibilit y study to determine if emissions from wildfires, prescribed b urns, and hazard reductions burns could be further reduced to improve air quality. I n May 2009, District staff completed this feasibility study, after consulting stakeholders, a nd found that the enormous and untimely emissions produced by wildfires can be reduced by i ncreasing and modifying prescribed burning, pile burning, and hazard reduction burning practices. The feasibility study determined that in order to prevent wildfire emissi ons, the following actions would be required: 1) increase legislative action for more p rescribed burning resources, implement policy modifications to raise the priority of air q uality-related public health concerns; 2) coordinate efforts between multiple agencies; and 3 ) allocate time for public education.

The District is proceeding with actions recommended by the feasibility study. In May 2009, the District’s Governing Board approved an am endment to the District’s 2009 Legislative Platform to include a recommendation fo r Curbing Wildfires and the Associated Adverse Public Health Impacts. The Dist rict’s 2010 Legislative Platform continues to include a recommendation for Curbing W ildfires and the Associated Adverse Public Health Impact. Furthermore, during the wild fire and prescribed-burn season, the District participates in daily coordination calls w ith multiple agencies, including land management associations, as needed. The District h as also developed brochures and hosts a webpage to educate the public on hazard-red uction burning, issues daily burn forecasts, and provides the public with a phone num ber to obtain additional information about hazard-reduction burning and prescribed burni ng including daily prohibition updates.

3.2.3 Open Burning Biomass Incentive

Both the 2007 Ozone Plan and the 2008 PM2.5 Plan committed the District to conduct a feasibility study for emissions reductions through Open Burning Biomass Incentives. The source category, qualified agricultural biomass (QA B), is defined as agricultural material, which may be considered for on-site open burning, b ut could be diverted to a biomass power plant for use as fuel, thus reducing signific ant emissions inherent in the open burn process. Such materials include various pruning ma terial, orchard and vineyard removal material, and rice, wheat, and barley straw. Agric ultural material burned in combustors at a biomass power plant is used to produce steam, whi ch then spins turbines to generate electricity. Burning of agricultural material is o n option for compliance with District Rule 4103. Additionally, for the most part, such electr icity is sold to utility companies to meet their renewable energy resource commitments as a pa rt of the California Renewable Portfolio Standard (RPS) established by Senate Bill 1078.

During the feasibility study process, District staf f identified an opportunity to achieve
emissions reductions from such QAB. The District s tudy showed that approximately 149,567 acres, equating to 483,316 tons of agricult ural material, were approved for open burning in 2008, thus generating 4.55 tpd of PM2.5 and 3.46 tpd of NOx. The nine biomass power plants in the Valley burn an average of 1,474,051 bone-dry tons (BDT) of biomass fuel each year. Staff estimates that in 20 08, approximately 25% of the BDT was QAB. The 2008 Emission Inventory for biomass power plants was approximately 0.52 tpd of PM and 1.55 tpd for NOx.32 SJVAPCD 2010 Ozone Mid-Course Review

Certainly, the open-burn option is generally the le ast costly option for growers; however adherence to regulatory burn schedules sometimes pr ohibits efficient and timely removal of agricultural material. An alternative option fo r growers is to contract a chipper to dispose of the agricultural material. The chipper, in turn has the option of paying to have the material disposed of at a landfill or compost f acility, or being paid for the material by a biomass power plant. However, it is generally more economical for the biomass power plants to buy urban biomass fuel instead of agricul tural fuel. In recent years, due to the economic downturn and resulting lack of available u rban waste, the biomass power plants have increased the use of QAB as fuel. Dist rict staff believe that when the economy recovers and urban waste fuel becomes more readily available, the biomass power plants will reduce acceptance of QAB in favor of the less-expensive urban fuel; thus the future supply of QAB fuel may be more than future demand of such fuel at biomass power plants in the Valley, creating an eco nomic disincentive for the use of QAB

as a biomass fuel source.

To counteract the economic disincentive for biomass power plants to accept agricultural material as fuel, District staff recommended the de velopment and implementation of an incentive program to increase the use of QAB as fue l for biomass power plants. District staff found that there are no long-term federal or state funding commitments for biomass power plants in place at this time, nor are they aw are of any federal or state funding programs that are in the planning stages. While th ere is currently no direct source for such incentive funding, the District will seek out opportunities for securing a dependable source of funding to subsidize the increased uptake of agricultural biomass fuel on the demand side of the economic equation.

Given that are two distinct advantages in routing Q AB through a biomass facility: 1) reductions in criteria pollutant emissions compared to open burning; and 2) production of electricity that aids the utilities in meeting the RPS; development of a program for biomass incentives would help to sustain a technolo gy that has shown to be a feasible and cost-effective alternative to open burning for many crop types in the Valley.

3.2.4 Crude Oil Production Sumps

The 2007 Ozone Plan

committed the District to conduct a feasibility st udy to evaluate the potential for VOC emissions reductions from primary , secondary, and tertiary oil field sumps for heavy, intermediate, and light oil. The intent of the feasibility study was to

determine if amendments to District Rule 4402 or 47 23 could reduce VOC emissions

from these sources.

The District has reviewed the BACT database, permit database, and rules of other air districts to identify potential controls. Staff id entified potential options including: requiring covering of sumps, prohibition on sumps except for use as emergency outlets, requirement to utilized closed tanks with PV valves in lieu of sumps, and adjustment of exemption levels.

The District is currently reviewing and refining th e emission inventory for this source category. The District has reviewed the permit dat abase, acquired information from the regional water board, acquired information from the California Division of Oil, Gas, and Geothermal Resources, worked with ARB to obtain inf ormation from survey results, andSection 3 – Regulatory Control Measures 33

spoken with industry representatives to estimate th e number and surface area of each type of sump. The District is currently working to reconcile the discrepancies in the number and surface area of sumps provided by each i nformation source. The District is also evaluating the cost and impact of various cont rol options and considering voluntary options to reduce emissions. At this time it appear s that the potential for VOC emission reductions may be low considering the small invento ry of sumps in the Valley. Completion of this feasibility study is anticipated for 2010.

3.2.5 Heavy Crude Oil Components

The 2007 Ozone Plan

committed the District to conduct a Feasibility St udy to evaluate the potential of VOC emissions reductions through t he prevention of oil leaks in production of heavy crude oil in Valley.

District staff analyzed the costs and cost-effectiv eness of controlling leaks from heavy oil components by requiring periodic inspections of the components. Additionally, staff refined the inventory with information obtained fro m the state and crude oil and natural gas stakeholders. Based on the analysis District s taff is not recommending a VOC rule project for this source category at this time, citi ng that the potential for VOC emission

reductions was limited and the cost effectiveness f or VOCs alone was higher than recent VOC rule projects. The District does not have the authority to regulate air pollutants other than criteria pollutants (VOC, NOx, SOx, PM2. 5, and PM10) so cannot consider greenhouse gases such as methane and ethane when ev aluating the feasibility of a control measure. However, ARB does have the author ity to regulate greenhouse gases. Since 61 percent of fugitive emissions from oil and gas production is in the form of methane and ethane, ARB is in the process of evalua ting this source category as a greenhouse gas reduction measure for meeting AB32 r eduction goals. Any actions to reduce greenhouse gas from heavy crude oil componen ts will have a co-benefit of reducing VOC emissions. The District will monitor A RB’s progress closely and evaluate their reduction measure in light of concurrent VOC reductions that will benefit Valley air quality.

3.2.6 Solid Fuel Fired Boilers

Both the 2007 Ozone Plan and the 2008 PM2.5 Plan committed the District to conduct a feasibility study to determine if additional emissi ons reductions could be achieved through amendments to Rule 4352, Solid Fuel Fired Boilers, Steam Generators, and Process Heaters. This source category includes facilities that operate boilers, steam generators, and process heaters (hereafter referred to as “unit s”) that are fired on solid fuel. The units are used in facilities that generate utility and industrial power (electricity and heat) by burning solid fuels including petroleum coke, co al, municipal solid wastes, tires, biomass wastes, urban and construction wood wastes, or any combination thereof.

The District’s analysis showed that it may be techn ologically feasible to control NOx emissions with Selective Catalytic Reduction (SCR) or hybrid SNCR/SCR. Additionally, there are boilers that are operating at emission le vels below the limits stated in District

Rule 4352. No additional PM2.5 emission reduction could be achieved because existing units in the District already operate fabric filter s/baghouses and/or electrostatic precipitators, which are considered as Best Availab le Control Technology (BACT) for this source category. The units are already operating l ime injection or soda ash injection,34 SJVAPCD 2010 Ozone Mid-Course Review

which are considered BACT for this source category, so there is no additional SOx

emission reduction from the current level.

Because of the potential for NOx emissions reductio ns, a rulemaking project will be scheduled for the next available opportunity to con sider additional controls and lower limits for solid fuel fired boilers, steam generato rs, and process heaters, in addition to addressing EPA concerns regarding the current Distr ict Rule 4352.

3.2.7 Small Boilers

The 2007 Ozone Plan

committed the District to conduct a Feasibility St udy to re-evaluate the potential of further NOx emissions reductions f rom boilers, steam generators, and process heaters rated at 0.075 to less than 2.0 MMB tu/hr subject to District Rule 4308.

Staff completed the Feasibility Study in 2009 and i nitiated a rule amendment project to establish more stringent NOx emissions limits for u nits running on PUC-qualified natural gas. The District Governing Board adopted Amended Rule 4308 on December 17, 2009. Amendments approved by the Board included eliminati on of the previous exemption for humidifiers, addition of an exemption for recreatio nal vehicles, reduction of the emission limits for most categories, and adjustment to the c ompliance schedule for the rule. The rule achieved a 75 percent reduction in emissions f rom small boilers rated from 0.075 to less than 0.4 MMBtu/hr. The rule achieved an 85 pe rcent reduction in emissions from

small boiler rated from 0.4 to less than 2.0 MMBtu/ hr. Overall, the rule achieved an 82 percent reduction in emissions from the entire sour ce category for boilers, steam generators, and process heaters rated at 0.075 to l ess than 2.0 MMBtu/hr, which takes

into account that there are more small boilers rate d from 0.4 to less than 2.0 MMBtu/hr

than less than 0.4 MMBtu/hr. The cost effectivenes s of this rule was estimated at $1,500 to $2,000 per ton of NOx reduced for individual uni ts. A co-benefit achieved from this

rule amendment was reductions in GHG emissions due to replacement of uncontrolled units operating at low efficiency with high efficie ncy units.

3.3 Summary of Regulatory Control Measures

The District has met all of its commitments with re gard to rulemaking and feasibility

studies as identified in the 2007 Ozone Plan. Through the rulemaking process to date,

the District identified additional emissions reduct ions in the amount of 8.0 tons per day of NOx and 3.2 tons per day of VOC. Results from the feasibility studies initiated to date have yielded one completed rule (emissions included in additional emissions above) and a future rulemaking project with anticipated emissi ons reductions of two to three tons per day of NOx. Additionally, the feasibility studies identified potential incentive program opportunities to further reduce emissions.Section 4 – Indirect Source Review 35 

## Section 4 - Indirect Source Review

While the District has made significant gains in re ducing emissions from stationary sources through District regulations, growth in are a-wide and motor vehicle emissions has diminished the overall effect of such regulatio ns. The past and expected increases in population and VMT, as shown in Section 2, add to t he fact that mobile sources remain the largest source of NOx emissions, comprising 78 percent of the Valley total in 2008. Since state and federal motor vehicle regulations w ere not achieving the necessary results to meet NAAQS attainment deadlines, the Dis trict sought to reduce such emissions indirectly.

District Rule 9510, Indirect Source Review (ISR) sp ans the gap between regulatory control measures and incentive programs developed b y the District for emissions reductions. ISR was developed from an emissions re duction commitment made in the

2003 PM10 Attainment Plan and the EOADP . Rule 9510 was adopted by the District’s Board on December 15, 2005, with an effective date of March 1, 2006, to reduce the growing impacts of emissions resulting from the lan d development in the Valley.

During the ISR process, District staff evaluate pro jects for baseline NOx and PM emissions and potential reductions based on constru ction, design, and ongoing operations. For emissions not mitigated on-site, R ule 9510 has an established fee schedule to account for any off-site emissions requ ired to meet reduction requirements

as follows:

Year NOx ($/ton) PM10

($/ton)

2006 $4,650 $2,907

2007 $7,100 $5,594

2008 & beyond $9,350 $9,011

To date, the District has reviewed and approved 447 development projects under ISR. Based on this review and approval, 2,660 tons of NO x and 1,692 tons of PM emissions have been reduced through on-site mitigation, eithe r in the construction of operational phases. Through the review of these projects, the District has also collected $9,741,116 in off-site mitigation fees to mitigate 2,495 tons of NOx emissions and 2,298 tons of PM10 emissions that developers were not able to ach ieve through on-site emission

reduction measures.

While the District has collected off-site mitigatio n fees, litigation against the District over the ISR Rule has delayed expenditure of the majorit y of funds. On June 27, 2006 a lawsuit was filed by various building industries ch allenging the validity of Rule 9510. On March 25, 2008, the Fresno County Superior Court ru led in favor of the District on all accounts. An appeal of that decision was filed May 22, 2008. A recent court decision on this appeal upheld the ISR rule as a valid exercise of state law authority. However, a companion case, challenging the construction portio n of the rule on federal law grounds,36 SJVAPCD 2010 Ozone Mid-Course Review

is pending before the Ninth Circuit Court of Appeal s. Accordingly, while the District has recently been able to release the operational phase fees for expenditure, the construction phase fees are on hold pending resolution of the fe deral lawsuit.

4.1 On-Site Emissions Reductions & Off-Site Emissio ns Mitigation ISR applies to new development projects that emit e missions of at least two tons of NOx or two tons of PM10 per year. The rule contains pr ovisions exempting traditional stationary source projects that are subject to the District’s stationary source permitting requirements. Developers of projects subject to IS R must reduce emissions occurring during construction and operational phases of a dev elopment project. During construction, exhaust emissions of NOx and PM10 are to be reduced by 20 and 45 percent, respectively. Construction exhaust emissi ons can be reduced through

installation and use of aftermarket devices or thro ugh the use of construction equipment that is newer than the statewide average. Operatio nal emissions of NOx and PM10 are to be reduced 33.3 and 50 percent, respectively, fr om the project baseline for 10 years. Operational emissions can be reduced through any co mbination of land-use decisions, project design element, and building construction.

If a developer cannot achieve the required emission reductions through onsite measures, the rule provides a mechanism by which the develope r can pay an offsite mitigation fee to the District. One hundred percent of all offsite m itigation fees received by the District are to be used to fund emission reduction projects, ach ieving emission reductions on behalf the original project.

In an effort to avoid mitigation fees, developers i ncorporate many air-friendly operational and design components into their proposals. At the time of initial construction, significant emissions reductions are garnered through the use o f modern or retrofitted construction equipment. In planning for operational emissions r eductions, developers and site users can make provisions for the use of cleaner fleets, which are especially significant for large distribution centers. Design features, such as installation of solar power, integrated mixed-use development, pedestrian connectivity and high-efficiency housing and building design, cumulatively add up to significant emission s reductions.

4.2 Mitigation Fees for Incentives In light of the legal issues related to ISR, the ma jority of funds have remained on hold pending court decisions. The District was however able to utilize $2 million in an innovative effort to reduce regional emissions in t he Valley. The District collaborated with the Natural Resources Conservation Service (NRCS) t o co-fund agricultural tractor replacement projects using $2 million of ISR off-si te fees. Funds utilized by the NRCS were provided through the Environmental Quality Inc entives Program (EQIP) Conservation Innovation Grants (b) [CIG (b)] portio n of the 2008 U.S. Department of Agriculture Farm Bill.

The District and NRCS combined funding to replace e xisting, in-use agricultural tractors equipped with uncontrolled (Tier 0) engines with ne w tractors equipped with Tier 3 or cleaner engines. Total funding provided by both ag encies paid up to 70% of eligibleSection 4 – Indirect Source Review 37

tractor costs. In an effort to achieve maximum emi ssions reductions, the District ranked all eligible project applications received and only selected the most cost-effective projects to co-fund. In total, the District was able to co- fund 84 projects, replacing 102 tractors. For 21 projects, two existing tractors were replace d with one new tractor.

The following table summarizes the estimated lifeti me emissions reductions achieved for all projects co-funded with the $2 million ISR fees :

Number of Co-funded Projects: 84

Project Life: 10 years

Project PM Reductions: 43 tons

Project NOx Reductions: 1,172 tons

4.3 Summary of ISR While utilization of off-site mitigation funds for incentive programs for primarily mobile sources was anticipated beginning in 2006, these fu nds have been sequestered in light of litigation, thus anticipated emissions reductions a re not yet realized. Recent legal decisions have the effect of releasing approximatel y $7 million for District use in emissions reductions projects. While the District anticipated a steady utilization of these funds for incentive programs, full implementation s hould result in intensified emissions reductions over the next few years and help to main tain the increased rate of reductions subsequent to 2005. Through established accountabi lity measures, ISR ensures that the District will utilize off-site fees to fund quantif iable and enforceable off-site projects that reduce surplus emissions of NOx and PM10.38 SJVAPCD 2010 Ozone Mid-Course Review This Page Intentionally BlankSection 5 – Incentive Programs 39 

## Section 5 - Incentive Programs

While the District’s regulatory control of stationa ry sources has been successful in reducing precursors to ambient ozone formation and will continue to be successful in that regard with the implementation of control measures identified in the 2007 Ozone Plan , 80 percent of the Valley’s NOx inventory is produced b y mobile sources, either those within the Valley or those that travel through the Valley. Because of its limited authority to regulate such mobile sources, the District has deve loped other non-regulatory emissions reduction strategies to accelerate attainment of th e 1-hour and 8-hour ozone NAAQS by federal deadlines or before. Such strategies are a major component of the District’s 2007

Ozone Plan

“black box” approach approved by the EPA given the Valley’s extreme 8- hour ozone designation. The 2007 Ozone Plan , identified all emissions reductions given known and prospective technologies; however, these technologies to not result in sufficient federally creditable reductions for atta inment of the 8-hour ozone NAAQS in the Valley. The “black box” contains those measures, i ncluding potential regulatory and nonregulatory measures identified in feasibility studi es subsequent to attainment plan adoption, that incentivize voluntary reductions or utilization of newer technologies when not immediately economically feasible for a given s ource category.

The District’s highly successful Emissions Reductio n Incentive Program (ERIP) is one strategy that provides such non-regulatory emission s reductions. Without the increase in incentive measures and incentive funding identified in the 2007 Ozone Plan, attainment of the 8-hour ozone NAAQS would be delayed to after 2020 for over 1,000,000 Valley residents. To accomplish reaching early attainment , approximately $200 million annually in funding is required until attainment is reached. Furthermore, without additional incentives, the Valley quite likely would not reach attainment of the PM2.5 NAAQS by 2015, as currently mandated by the CAA.

Through incentives, funding is provided for project s that achieve emission reductions prior to or beyond reductions required from rules a nd regulations. Most importantly,

incentives allow the District to reduce emissions f rom source categories outside of the District’s regulatory authority, as well as source categories where financial hardship would otherwise prevent traditional control strateg ies from being implemented.

5.1 Ongoing Incentive Programs Since 1992, the District has gained significant exp erience in developing and implementing successful incentive programs. The fu nding for such programs has expanded over the years, as has the sophistication and diversity of programs offered by the District. The District is currently operating three primary incentive programs aimed at reducing precursor emissions: the Heavy-Duty Engin e Emission Reduction Incentive Program (Heavy-Duty Engine Program), the Reduce Mot or Vehicle Emissions II (REMOVE II) Program, and Community Based Incentives . These overarching programs offer incentives to businesses, public agencies, an d the general public for a wide variety of emissions reductions projects including the Lowe r Emission School Bus Program, the Burn Cleaner Wood Stove Change Out, and the Station ary Agricultural Irrigation Pump replacement program as opportunities to achieve cos t-effective emission reductions40 SJVAPCD 2010 Ozone Mid-Course Review

present themselves and funding becomes available, t he District has been willing to develop new programs and new components for existin g programs.

The amount of funding currently available to the Di strict for incentive-based programs is over $100 million per year. The primary sources fo r these funds are the expected

revenues from the District’s Indirect Source Review Rule, voluntary development mitigation agreements, local DMV surcharge fees, th e state’s Carl Moyer Program, Proposition 1B, and various federal funds.

In 2008, the District consolidated advocacy efforts in order to secure additional funding under the State Proposition 1B Goods Movement Emiss ion Reduction Program (Prop 1B) for the San Joaquin Valley. The Prop 1B program pr ovides incentive funds to retrofit or replace diesel engines in heavy-duty trucks, locomo tives, and harbor craft that are used to transport goods in California. The District was awarded approximately $46 million for the first year of the Prop 1B programs. In light o f California’s current fiscal situation, the second year of program funding was delayed and will be combined with the third year funding allocation. The District expects to be awar ded approximately $92 million in June 2010 for eligible equipment projects.

Table 5-1 identifies the individual incentive progr ams that the District has or is administering, including the total funding amount f or each program, how many projects were funded for each program, and the applicable NO x and VOC emissions reductions attributable to each program.

Table 5-1 Incentive Program Totals, 1998 - 2009

Program Total Grant # of Projects NOx

(tons) VOC

(tons) Agricultural Engine $92,227,136 2,399 44,831 2,019 Alternative Fuel/Hybrid Vehicle

Rebate $39,930 4 NC NC

Bicycle Infrastructure $739,029 14 11 17 Car Crushing $1,439,150 524 19 29 Commuter Subsidy $948,531 172 26 21

Electric Forklift $346,598 7 43 2 E-Mobility $333,764 6 4 3

Infrastructure $2,931,913 15 NC NC
Lawn Mower Replacement $857,303 5,508 NC NC Light and Medium Duty $323,000 28 NC NC

Locomotive $13,093,912 5 574 28 Off-Road Heavy Duty $35,974,821 560 7,223 349 On-Road Heavy Duty $31,435,860 246 5,219 5 On-Road Heavy Duty Prop1B $6,702,500 70 1,492 NC On-Road Heavy Duty VIP $995,000 30 NC NC School Bus Replacement $17,227,215 49 NC NC

School Bus Retrofit $5,846,225 61 NC NC

Truck Electrification $1,753,000 1 2,634 NC Wood Stove Change Out $150,000 168 2 28

Totals $213,364,887 9,867 62,078 2,501

NC – Not calculatedSection 5 – Incentive Programs 41

Table 5-2 itemizes the total funding received each year from 1998 through 2009 and the associated surplus emissions reductions each year.

Table 5-2 Total Annual Incentive Funding 1998 - 20 09

Year Total Grant # of Projects NOx

(tons) VOC (tons)

1998 $3,552,526 25 722 NC

1999 $4,573,661 95 3199 NC

2000 $4,840,989 159 3426 NC

2001 $13,982,396 1,632 7149 NC

2002 $12,757,254 1,536 4656 NC

2003 $9,909,870 309 5769 NC

2004 $11,600,980 284 8190 NC

2005 $12,686,419 287 5188 60

2006 $42,615,609 1,253 6630 556

2007 $33,383,846 1,252 5903 597

2008 $30,983,877 1,327 5293 793

2009 $32,477,450 1,708 5,953 495

Totals $213,364,887 9,867 62,078 2,501

NC – Not calculated

In addition to applying for various funding sources , the District is working with ARB to make the Carl Moyer Program and the Prop 1B program s more flexible and streamlined to attract a greater pool of potential projects to fund. Over the last few years, ARB has adopted new rules and regulations that require emis sion reductions from sources that participate in the District’s incentive programs. As these sources approach compliance deadlines, the opportunities for awarding incentive funds for these projects become

reduced. The District and ARB are committed to wor k within the framework of these regulations to identify opportunities for continued funding. In addition, the District is working with ARB staff to identify sources and proj ect types for funding consideration.

5.2 Incentive Programs in Development In light of past successes and the ongoing need for additional emissions reductions, the District continues to develop new avenues for incen tive funding opportunities. The following programs are currently in development:

5.2.1 Technology Advancement Program (TAP) In addition to the traditional incentive programs t hat have been implemented, the District’s Governing Board recently adopted the Tec hnology Advancement Program (TAP). The primary goal of TAP is to advance techn ology and accelerate the accessibility of innovations that will bring about emission reductions as rapidly as practicable. This innovative strategy is discussed more fully in Section 6, but includes the42 SJVAPCD 2010 Ozone Mid-Course Review

procurement of incentive funding for research and n ew technology development. The program will position the District to identify and seek out its fair share of funding to overcome the barriers to technology adoption for ar eas of specific need in the Valley.

5.2.2 Air Quality Action Center for Technology & In novation for the Valley The District, in collaboration with Valley Universi ties, will establish the Air Quality Action Center for Technology and Innovation for the Valley (AQ-ACTIV). This will provide the District the opportunity to leverage available reso urces to build regional capacity for research, technology demonstration projects, and ex pended emissions measurement and testing in the Valley.

5.2.3 Energy Efficiency Funding Opportunities The District’s Fast Track Action Plan, which is dis cussed further in Section 6, identified energy efficiency and conservation as an important component in reducing emissions necessary to reach attainment of the Federal ozone NAAQS. The District has applied for State and Federal grants related to energy efficien cy and will be providing the lead role in the implementation of the California Energy Commiss ion’s (CEC) Small Jurisdiction Energy Efficiency and Conservation Block Grant Prog ram (EECBG). The EECBG will provide approximately $4 million to small cities an d counties throughout the Valley for energy efficiency retrofit projects in jurisdiction al facilities. Such projects include lighting replacements to energy efficient compact fluorescen t bulbs, LED street light retrofits, heating ventilation and air conditioning system upg rades, and motor and pump replacements to newer high-efficiency models.

5.2.4 Other State Funding Opportunities The District has taken the lead in preparing a numb er of regional and large-scale grant applications that will benefit air quality in the h opes of bringing much-needed funds into the Valley. Most recently, the District has receiv ed funding from AB 118 for the Lawn and Garden Equipment Replacement Program, the Statewide Zero-Emission All-Terrain Agricultural Utility Vehicle Incentive Program, and funding made available through the Diesel Emissions Reduction Act (DERA). DERA will f und projects such as school bus replacement and retrofit, agricultural irrigation p ump repowers, and the on-road heavy duty truck selective catalytic reduction (SCR) tech nology demonstration project. The District has also applied for funding through the D epartment of Energy (DOE), including funding available through the American Recovery and Reinvestment Act, the EPA’s Climate Showcase funding opportunity, and DERA Heav y-Duty On-Road replacements.

5.3 State Implementation Plan Creditability for Inc entive Programs Current federal policy limits the use of incentive- based emissions reductions to meet CAA goals in air quality plans. Projects in this categ ory usually involve sources outside the District’s regulatory authority and generally focus on reductions above and beyond those required by rule or regulation. However, in order to reach attainment and meet its air quality goals as identified in the District’s adopt ed air quality plans, some level of SIP creditability must be achieved for emissions attain ed through its incentive program. The District is working closely with the EPA to identif y and implement procedures and protocols to ensure that emissions reductions will eventually be applied to the SIP. To that end, the District has established the framewor k for enforcement and accountability that will need to be in place to ensure success.Section 5 – Incentive Programs 43

The District’s incentive program infrastructure alr eady has the core elements that contribute to the creditability of emission reducti ons in the SIP. These elements include increased post-project monitoring, verification of emission reductions and comparison with predicted reductions, real-time reporting of e mission reductions with associated preparation of annual reports, and development of p rogram elements such as protocols in a transparent and open process. The District ha s continued to create and implement incentive programs in a manner consistent with thes e principles. The majority of the District’s incentive programs are funded by sources that establish program implementation guidelines that generally conform to these SIP-creditable principles.

5.4 Summary of Incentive Program Success To date, the District has successfully reduced ozon e precursor emissions through its aggressive Emissions Reduction Incentive Program. Over the twelve years of active incentive program implementation NOx and VOC emissi ons have been reduced by 62,078 tons and 2,501 tons, respectively. In addit ion to the emissions saved, the District was successful in bringing more than $213 million i n grant funding into the Valley to support not only the emissions reductions, but also the regional economy.

The District is committed to making the air quality goals of 2007 Ozone Plan attainable by aggressively seeking additional funding sources and modifying current incentive programs to improve efficiency, streamline grant pr ocesses, and increase applicant participation.

The District’s incentive programs have not only pro ven to be a highly cost-effective method for improving Valley air quality, but have b ecome a model for incentive programs throughout the state. In recent state audits, whic h included the Bureau of State Audits, ARB Carl Moyer Program, and State Department of Fin ance, the District was noted for its efficient, robust, and effective use of incentive g rant funds in reducing air pollution. Because of this recognition, numerous other Califor nia air districts have approached the

District to either assist with incentive fund admin istration or to accept their unused funds as an alternative to returning funds to the State. Most recently, the District has successfully partnered with the Great Basin, Kern C ounty, Antelope Valley, Mojave Dessert, Mariposa County, and Calaveras County air districts.44 SJVAPCD 2010 Ozone Mid-Course Review This Page Intentionally BlankSection 6 – Innovative Strategies 45 

## Section 6 - Innovative Strategies

The District’s ability to develop stringent, yet ec onomically feasible stationary source regulations and secure much-needed incentive and gr ant funding for air quality benefits is second only to its ability to successfully utilize and develop innovative strategies to

maximize emissions reductions across all sectors of the Valley. This component of the District’s multi-faceted approach toward the attain ment of federal health standards has become a critical means to achieve potential “black box” reductions. These innovative strategies are designed to enlist the public, local governments, businesses, and industry as willing contributors to a successful clean air s trategy.

To date, the implementation of such innovative stra tegies has led to increased public awareness of air quality issues, increased public p articipation towards air pollution solutions, and improvement in air quality in the Va lley. This broad spectrum of involvement will be critical in helping the Distric t reach attainment by the 2023 deadline.

6.1 Healthy Air Living Healthy Air Living is a comprehensive, year-round outreach initiative that aims to improve the health and quality of life of all Valley residents through ind ividual and collective strategies that reduce emissions. The g oal is to create an environment where air quality becomes a priority in the decision making process and the day -to-day choices made by individuals and businesses. Health y Air Living has become the District’s hallmark program a nd now encompasses all regulatory and voluntary emissi onreduction measures. The slogan, “Make One Change,” and the colorful, distinctive Healthy Air Living lo go brand all outreach materials and advertising.

Although only recently implemented, Healthy Air Liv ing has already produced several high-profile, high-participation campaigns, includi ng the Kids for Clean Air pledge card contest and an annual hybrid vehicle giveaway. The strategy of Healthy Air Living strategy is simple: give people the tools to make c lean-air choices that work in their lives, and they will commit to healthier lifestyles. Heal thy Air Living aims to reduce emissions through a variety of ways on both individual and or ganizational levels, including: reducing the number of vehicle miles traveled each day throu gh the Valley; reducing emissions during peak smog episodes; reducing emissions creat ed by equipment and processes; and encouraging higher energy efficiency and the de velopment of cleaner energy

sources.

6.2 Fast Track Measures On June 21, 2007, the District Governing Board adop ted a “dual path” strategy to attain the 8-hour ozone NAAQS as expeditiously as feasible . This strategy included the regulatory measures identified in the 2007 Ozone Plan to satisfy legal mandates under the CAA and a Fast Track Action Plan designed to be a dynamic non-regulatory air quality management strategy to capitalize on evolvi ng technologies, market opportunities,46 SJVAPCD 2010 Ozone Mid-Course Review

and public funding mechanisms to accelerate attainm ent of the 8-hour NAAQS prior to

the 2023 federal deadline.

The following sections describe the innovative stra tegies developed by the District to implement the Fast Track Action Plan.

6.2.1 Advanced Emission Reduction Options (AERO) The District has imposed Reasonably Available Contr ol Technology (RACT) and at least one generation of Best Available Retrofit Control T echnology (BARCT) on virtually all of the stationary sources in the Valley. As the Distr ict continues to implement its clean air strategy, some industries have implemented fourth a nd fifth generations of BARCT. In developing the 2007 Ozone Plan , District staff investigated every known source of emission reductions and proposed measures to pursue , including regulations to address mobile sources and another generation of regulatory controls on stationary sources.

Despite effective control measures for emissions re ductions, including past, current, and proposed control measures, there remains a signific ant need for additional reductions. Attaining the 8-hour ozone standard requires emissi on reductions of approximately 75 percent from 2005 levels. Because of this need, th e District has and will continue to seek to reduce emissions from source categories and indu stries that have been previously controlled, although continued generations of emiss ions from previously regulated sources are increasingly more expensive, thus less cost-effective.

The AERO program sets emission reduction goals for stationary sources based on advanced technologies, but also provides several op tions that operators could use to comply when unable to utilize such advanced technol ogies. The specified emission reduction options would include control of the subj ect equipment, mitigation fees, specified offsite reductions, and alternative onsit e approaches. All of these options would be well in excess of previously established RACT an d BARCT levels. Each option will have adequate provisions to ensure reductions are s urplus, enforceable, quantifiable, and permanent. During each rulemaking project, Dis trict staff will determine if benefits could be achieved through AERO provisions being inc orporated into the rule.

6.2.2 Alternative Energy The use of alternative sources of energy reduces an d slows the growth of NOx emissions from utility power generation. In real terms, the viability of alternative energy sources depends on the cost comparison to traditional energ y sources, generally the combustion of fossil fuels. Potential alternative energy sour ces include, but are not limited to: landfill gas; VOC and methane from confined animal facilitie s; agricultural waste products such as prunings, rice stalks, and orchard removal mater ials; biosolids; VOC from oil and gas production plants and other industrial facilities t hat are incinerated using flares or thermal oxidizers; solar; and hydrogen fuel cells.

The District has developed resources to promote alt ernative sources of energy, supported efforts promoting alternative energy, and aligned the District programs with initiatives that promote alternative energy, includ ing utilizing ERIP funding for alternative fuel vehicles. Additionally, as part of the 2010 L egislative Platform the District committed to supporting legislation that provides additional biomass capacity utilizing agriculturalSection 6 – Innovative Strategies 47

materials and expanding net metering and feed in ta riffs for the utilization of solar and other renewable sources of energy.

6.2.3 Energy Conservation The District has taken several steps to increase en ergy efficiency that will specifically benefit the Valley through improved air quality and reduced energy costs. In addition to having energy efficiency listed as a priority on th e District’s 2010 Legislative Platform, the Governing Board approved the District’s Regional En ergy Efficiency Strategy (REES) in January 2010. The District’s proactive role as a r egional leader in energy efficiency will put the Valley in a position to participate in new state and federal initiatives and funding opportunities to bring additional resources to the District that will further reduce greenhouse gas emissions, NOx emissions and lead to improved air quality.

The REES is being implemented through a coordinated and collaborative process that engages regional partners and stakeholders, includi ng potential recipients of proposed tools and programs. Towards that end, the District is working in a regional framework to: educate energy users as to the financial and air qu ality benefits of energy efficiency; identify regional barriers that have prevented maxi mum utilization of energy efficiency options in the past; work closely with San Joaquin Valley utilities, other public and nonprofit agencies, and local energy experts to lev erage the maximum support, services, expertise, and funding for unlocking the energy eff iciency potential; and develop a reliable and sustainable funding stream to incentiv ize energy efficiency and encourage development and utilization of new energy efficienc y technologies.

Currently the District is serving as a role model f or other entities by evaluating their own energy efficiency and conservation practices. Thro ugh the efforts of a District Energy

Conservation Committee established to evaluate the internal energy policies and usage patterns, the District identified no-cost and low-c ost energy conservation and waste minimization opportunities within its offices. Man y of these measures can be readily applied to other businesses. The District is willi ng to share the lessons they have learned

with other entities.

Preliminary calculations indicate that the District ’s efforts to reduce emissions through coordinated energy efficiency programs and activiti es throughout the Valley have the potential for reducing NOx emissions by as much 2.8 tons per day. This assumes that gross residential energy use can be reduced by an o verall 20 percent and gross nonresidential electricity use can be reduced by 15 pe rcent. Complexities in the import and export of electricity across regional boundaries wi ll affect the ultimate realized reductions. Achieving such gross reductions across all economic sectors will require and effective and coordinated regional effort, one which the Dist rict is prepared to facilitate.

6.2.4 Episodic & Regionally-Focused Controls Advances in real-time air quality measurement and m eteorological forecasting have made it possible to apply regulatory controls in a more focused manner. Examples of this concept include the District’s Smoke Management Pro gram and the “Check Before You Burn” Program that implements Rule 4901 (Wood Burni ng Fireplaces and Wood Burning Heaters). Both programs use real-time meteorologic al measurements and emissions estimates to determine if next-day conditions are c onducive to violations of ambient air48 SJVAPCD 2010 Ozone Mid-Course Review

quality standards. The District’s forecasters prep are and issue forecasts that can result in episodic and county-specific prohibitions on pre scribed burning, agricultural burning, and residential fireplace burning.

Banking on the success of these programs, the Distr ict believes that episodic and regionally focused controls could be used to “surgi cally” control emissions during the worst days of the ozone season. The District will consider episodic controls and regionally-focused controls during each rule develo pment project in order to optimize the benefits of each measure. Some of the source categ ories that may also be evaluated for possible episodic/regional controls include: recrea tional vehicles, including dirt bikes and power boats; non-essential structural painting and related activities; non-essential through-truck traffic in urban areas; industrial ac tivities amenable to postponement; diversion of heavy duty diesel truck traffic from H ighway 99 to Interstate 5; and nonessential use of lawn care equipment.

6.2.5 Green Contracting Green Contracting is a practice that may be used by public agencies to give preference points when awarding contracts to companies that us e low-emission fleet vehicles and equipment, and to those that actively promote rides haring programs. Contracts awarded to companies with “green” practices could also cont ain clauses that require participation in District Spare the Air activities. While the Di strict does not have regulatory authority to require local government agencies to adopt these or dinances, many have done so voluntarily, and more might be inclined to do so if assistance was provided. To promote green contracting practices in the Valley, the Dist rict will:

• Develop a model resolution, or policy, and promote its adoption by cities and counties;

• Make Green Contracting an attractive option for con tractors by awarding incentive funding for the retrofit of off-road cons truction equipment, vehicle fleets, and other equipment;

• Issue “Green Contractor Certification” to companies that fulfill minimum criteria, such as meeting advanced fleet standards; and

• Explore the possibility of increasing the District’ s mandate for requiring Green Contracting practices in public projects through le gislative changes to public

law.

6.2.6 Green Fleets The goal of this Fast Track Measure is to encourage both private and public fleet turnover through incentives and state regulations. Adopting a green fleet program can have major benefits, including reduced operating costs, decrea sed greenhouse gas and criteria pollutant emissions, and improved organizational re putation. The District has achieved significant emissions reductions from encouraging f leet turnover through incentive funding. Emissions reductions from greening fleets are expected to continue in the next few years through Proposition 1B and other funding sources.

6.2.7 Heat Island Mitigation The Heat Island Mitigation Fast Track Measure will encourage jurisdictions to adopt methods and practices that would reduce surface tem peratures in urban areas.Section 6 – Innovative Strategies 49

Emissions reductions will result from lower energy consumption and decreased temperatures will slow the formation of ozone from VOCs and NOx. To promote heat island mitigation measures, the District will:

• Develop a model resolution or policy for heat islan d mitigation and promote its adoption by cities and counties, including providin g incentive funding to seed projects;

• Encourage practices conducive to heat island mitiga tions through informational educational opportunities and incenti ves;

• Include elements of heat island mitigation as a com pliance option for facilities;

and

• Support research that adds certainty to the emissio n reduction potential or benefits of heat island mitigation programs.

The District is currently working with the Universi ty of California at Davis on a project to assess the benefits of implementing heat island mit igation practices in Fresno.

6.2.8 High Speed Rail In November 2008, Californians approved Proposition 1A, the Safe, Reliable, High-Speed

Train Bond Act , to provide $9.95 billion in bonds (with federal a nd private matching funds required) to establish a high-speed train service l inking Southern California, the Central Valley, and the San Francisco Bay Area. This proje ct has the potential to dramatically reduce passenger car trips through the Valley, redu ce emissions, and improve air quality. The California High Speed Rail Authority and partne rs are currently holding public meetings and workshops as they develop Environmenta l Impact Reports for each major section of the proposed railway. 8 District staff will continue to participate in ma ny of the meetings and workshops.

6.2.9 Inland Ports and Short Sea Shipping These two Fast Tracks initiatives could provide a v ery large emission reduction, but would require significant additional infrastructure , for which the District is actively lobbying for federal and state infrastructure funding. Addi tionally the District has facilitated meetings with Port of Oakland, Valley agricultural representatives, and other stakeholders to develop ideas for how to implement these two Fast Track initiatives.

Through the Fast Track process, the District has ta ken a leadership role, partnering with the Bay Area Air Quality Management District and th e Ports of Stockton and Oakland, in pursuing a “marine highway” system to reduce truck and travel between the Valley and

the Port of Oakland.

6.2.10 Truck Replacement/Retrofit District staff, in coordination with an advisory co mmittee, is currently working to use Proposition 1B funds to establish the most effectiv e program to reduce emissions from heavy-duty diesel trucks driven in the Valley. The District is currently processing grants for truck replacements, repowers, and retrofits fun ded by the state’s Proposition 1B

8 The annual report for this project can be found at www.cahighspeedrail.ca.gov/news/CHSRAProgramSummary ReportJuly2009.pdf

.50 SJVAPCD 2010 Ozone Mid-Course Review

Goods Movement Emission Reduction Program. Followi ng the close of the Year 1 solicitation period (7/5/08-9/5/08), applications f rom more than 600 different applicants and for 2,800 trucks were received. Once District staff verified eligibility, the qualified trucks were ranked based on the anticipated emissio n reductions that would be achieved by truck replacement, retrofits, and repowers. Not ices were sent to eligible truck owners informing them of their ranking on the list and pro spects for funding. Staff processed awards for roughly 790 trucks with the first year’s allocation of nearly $40 million and are gearing up to disburse approximately $92 million in grants in 2010.

6.3 Technology Advancement Program The Technology Advancement Program (TAP) represents a strategic and comprehensive program to identify, solicit, and support technolog y advancement opportunities and represents a significant step forward in fulfilling the District’s public health mission. The TAP’s primary goal is to advance technology and acc elerate the deployment of innovative clean air technologies that result in emissions red uctions as rapidly as practicable. While the primary focus will be on NOx reductions, to max imize administrative efficiency and funding opportunities, the District will integrate when possible grant programs for greenhouse gases and criteria pollutant emissions r eductions. The District will implement TAP through a coordinated and collaborative process that will engage technology developers and potential end-users as follows:

• Integrate of technology advancement goals into exis ting grant programs;

• Identify specific technology focus areas;

• Conduct comprehensive outreach;

• Review and obtain ongoing feedback on new technolog y concepts;

• Develop a competitive process for funding technolog y advancement projects;

• Partner with other agencies for regional and multi- agency efficiencies; and

• Build and expand local capacity for research and de velopment in the Valley.

6.4 Other Public Education, Awareness & Information

The Outreach and Communications Division’s mission is to further the District’s goals of improving air quality and protecting public health through education, partnership, outreach and cooperation with the media, public, bu siness, government, district employees and other stakeholders. To this end, thi s District Division leaves “no stone unturned” in taking every advantage to educate the public through public appearances and media events throughout the Valley. This commi tment also comes through with every employee’s interaction with the public in whi ch every customer service interaction becomes an opportunity to share information about w ays that every person in the Valley can participate in clean air practices.

6.5 Summary of Innovative Strategies Most of the innovative strategies discussed in this chapter are not yet SIP creditable; however, maximizing their effectiveness is critical for meeting NAAQS ozone attainment by or before 2024. While emission reduction succes s from implementation of the 2004

Extreme Ozone Attainment Demonstration Plan ( EOADP

) for the 1-hour ozone NAAQSSection 6 – Innovative Strategies 51

primarily relied on more effective regulatory contr ols on stationary sources at the District level and mobile-source regulations at the state le vel, such regulatory controls have become increasingly expensive for the regulated sou rce operators. The District’s need

for further reductions must be balanced with the ec onomic sustainability of the Valley. For this reason, further emissions reductions will rely heavily on innovation strategies

such as the ones described in this Section.

While implementing and fostering these activities i s no trivial task on the part of the District in terms of time and commitment, they can be fairly easy to implement for the public sector if they have information and valuable decision-making tools. In fact, in many instances such as reducing energy use and redu cing vehicle miles traveled,

consumers can also reduce their costs – a “win-win” for the District and the Valley.

To maximize the potential for receiving “black box” emissions reductions, the District must undertake this deliberative and strategic appr oach that involves the public, educational institutions, private technology innova tors, and state and federal agencies. Only through a comprehensive and well-documented ac counting of attempts and

successes will the District be able to access all a vailable emissions reductions opportunities on the road to attainment of the 8-ho ur ozone NAAQS.52 SJVAPCD 2010 Ozone Mid-Course Review This Page Intentionally BlankSection 7 – Federal, State & Local Controls 53 

## Section 7 - Federal, State & Local Controls

Responsibility for implementing emission reduction measures does not rest solely on the District’s shoulders, especially when it comes to e missions from mobile sources; rather it is shared between the District, the State Air Resou rces Board (ARB), other State agencies, the EPA, and local jurisdictions. Only t hrough the coordinated efforts of all these agencies will the goals of adopted air qualit y plans be met. Because motor vehicles are the largest source of ozone precursor emissions in the Valley, the District is in active partnership with federal, state, and loca l agencies to minimize the impact of motor vehicles on air quality. Such a partnership is crucial in addressing the difficult challenge of balancing the need to provide increase d mobility for the enhancement of the social and economic well being of the Valley, with the equally important goal of attaining healthy air quality for all the residents.

7.1 State & Federal Controls At the state level, ARB is responsible for controll ing emissions from: mobile sources and consumer products, except where federal law preempt s ARB’s authority; developing fuel specifications; establishing gasoline vapor recover y standards and certifying vapor recovery systems; providing technical support to th e districts; and overseeing local air district compliance with State and federal law. Th e State Department of Pesticide Regulation is responsible for control of agricultur al, commercial and structural pesticides, while the Bureau of Automotive Repair runs the Stat e’s Smog Check programs to identify and repair polluting cars.

The District’s 2007 Ozone Plan identified ARB’s statewide strategy to bring areas of the

state into attainment of both the federal PM2.5 and ozone standards. The currently quantified emission reduction estimates for the Val ley from the mix of concepts still under evaluation are shown in Table 7-1. Of significant importance are the anticipated emissions reductions to be gained from state regula tions for cleaner in-use heavy-duty trucks, totaling approximately 112 tons per day of NOx by 2023, and state regulations for off-road equipment, totaling approximately 13 tons per day of NOx by 2023.54 SJVAPCD 2010 Ozone Mid-Course Review

As EPA strengthens the NAAQS, new federal regulatio ns are being developed to assist air districts in reaching attainment. Upcoming or recently adopted regulations will limit emissions from federally controlled sources such as marine vessels, aircraft, locomotives,

and automotive fuel.

7.2 Local Government Commitments & Achievements Local governments also play a significant role in a ir quality improvements, given that vehicular movement, and associated emissions, to so me degree, is within the control of the jurisdiction through development and transporta tion policies and codes. Federal and state legislation affect all levels of local govern ment through transportation planning and Table 7-1 Valley Emission Reduction Estimates* fro m Near Term Measures Under

Evaluation for State & Federal Measures

2014 2020 2023

NOx VOC NOx VOC NOx VOC Proposed New SIP Measures

tons per day

ON-ROAD SOURCES Passenger Vehicles 3.8 6.5 2.7 4.1 2.1 3.3 Smog Check Improvements (BAR) 3.3 2.9 2.4 2.2 2.1 1.9 Expanded Vehicle Retirement 0.5 0.7 0.3 0.3 0.0 0.1 Modifications to Reformulated Gasoline Program -- 2.9 -- 1.6 -- 1.3

Trucks 61.4 6.4 30.2 3.3 21.2 2.3 Cleaner In-Use Heavy-Duty Trucks 61.4 6.4 30.2 3. 3 21.2 2.3 On-Road Sub-Total for Conformity Budgets NA NA 32 .9 7.4 23.3 5.6

GOODS MOVEMENT SOURCES 7.2 0.5 15.6 1.2 16.4 1.3 Auxiliary Ship Engine Cold Ironing and Other Clea n Technology -- -- -- -- -- -- Cleaner Main Ship Engines and Fuel -- -- -- -- --
-- Port Truck Modernization -- -- -- -- -- -- Accelerated Introduction of Cleaner Line-Haul Loc omotives* 7.2 0.5 15.6 1.2 16.4 1.3 Clean Up Existing Harbor Craft
-- -- -- -- -- -- OFF-ROAD SOURCES Off-Road Equipment 4.8 0.8 4.9 0.8 4.0 0.6 Cleaner In-Use Off-Road Equipment (over 25hp) 4.8 0.8 4.9 0.8 4.0 0.6 Agricultural Equipment NYQ NYQ NYQ NYQ NYQ NYQ

Other Off-Road Sources 0.1 4.0 0.4 8.9 0.6 11.5

New Emission Standards for Recreational Boats 0.1 1.2 0.4 3.8 0.6 5.3 Expanded Off-Road Recreational Vehicle Emission S tandards -- 2.2 -- 4.0 -- 4.8 Portable Outboard Marine Tank Evaporative Standar ds -- 0.3 -- 0.5 -- 0.5 Refueling Gasoline Storage Tank Evaporative Stand ards -- 0.1 -- 0.4 -- 0.6 Gas Station Fueling Hose Evaporative Standards -- 0.2 -- 0.2 -- 0.3 Enhanced Vapor Recovery for Above Ground Storage Tanks -- NYQ -- NYQ -- NYQ

AREAWIDE SOURCES

Consumer Products -- 3.2 -- 3.6 -- 3.8 Consumer Products Program -- 3.2 -- 3.6 -- 3.8

Pesticides -- NYQ -- NYQ -- NYQ

DPR 2008 Pesticide Plan** -- -- -- -- -- -- Total Emission Reductions from Proposed New Measure s 77 21 54 22 44 23

NYQ – Not Yet Quantified

* The State of California’s commitments for ozone a ttainment in the San Joaquin Valley will be for emi ssion reductions in 2020 and 2023. Benefits in 2014 are provided for inform ational purposes only and may be revised as the ARB adopts and amends regulations. Current the In-Use Heavy-Duty Truck ru le is under consideration for amendment so the 2014 numbers for this rule may change. **The California Department of Pesticide Regulation (CDPR) is developing a suite of new pesticide emis sion reductions measures for inclusion in the Statewide Strategy. CDPR will provide the estimated benefits of these measures i n the future as part of the State Strategy.Section 7 – Federal, State & Local Controls 55

funding. The District works closely with the Metro politan Planning Organizations (MPOs) for all matters that pertain to transportation and air quality. Such coordination is critical for ensuring that air quality plan goals are attain ed.

7.2.1 Regional Transportation Plans At the county level, the Metropolitan Planning Orga nizations (MPOs), representing the eight counties in the Valley, work in concert with their numerous municipalities, unincorporated areas, public interest groups, the D istrict, and state and federal agencies to develop and maintain regional transportation pla ns (RTPs) that maximize efficient regional mobility and minimize unnecessary ozone pr ecursor emissions consistent with emissions budgets established in the SIP. Such reg ional emissions budgets serve as regulatory limits for on-road mobile source emissio ns. As a condition to receive federal transportation funding, transportation plans, progr ams, and projects are required to meet those emission budgets through strategies that incr ease the efficiency of the transportation system and reduce motor vehicle use.

Transportation plans and programs within the Valley are also required to conform to air quality plans in the region, as established by the CAA and reinforced by the Safe, Accountable, Flexible, Efficient Transportation Equ ity Act: A Legacy for Users (SAFETEA-LU). District staff review transportation plans and plan amendments to ensure such conformity. While Valley MPOs have lim ited legal authority to implement emission reduction measures, their status as Region al Transportation Planning Agencies places them in a position to help coordinate and fa cilitate consensus among their member jurisdictions, which do have authority to im plement local measures.

7.2.2 Conformity Budgets Section 176(c) of the CAA outlines its conformity p rovision. Federal actions are required to conform to the SIP’s purpose of eliminating or r educing the severity and number of exceedances of the NAAQS and achieving expeditious attainment of these standards. The CAA distinguishes transportation actions, or th ose actions undertaken by the Federal Highway Administration (FHWA) or the Federal Transi t Administration (FTA), from all other federal actions. MPOs must make findings tha t RTPs and transportation improvement programs (TIPs) conform to the SIP and submit such findings to the FHWA and FTA for approval. The conformity finding must demonstrate that the emissions

associated with the RTP and TIP do not exceed “emis sion budgets” that are contained in

the SIP. The District’s 2007 Ozone Plan established subarea emissions budgets for each county for VOC and NOx for 2011, 2014, 2017. On Ja nuary 22, 2009, these budgets were approved by the U.S. EPA and published in the Federal Register.

Both District and ARB control measures included in the 2007 Ozone Planthat affect onroad mobile sources have been included in the confo rmity emission budgets. These county-level emissions are shown in Table 7-2. Dis trict controls include: 1) Existing Indirect Source Mitigation and School Bus Fleets ru les; and 2) Rule 9410 – Employerbased Trip Reduction. ARB controls include: 1) Ex isting Reflash, Idling, and Carl Moyer Program emissions reductions; and 2) Proposed passe nger vehicle and truck measures included in the Draft State Strategy, as shown in T able 7-1.56 SJVAPCD 2010 Ozone Mid-Course Review Table 7-2 Transportation Conformity Budgets 1

2008 2011 2014 2017 2020 2023 County VOC NOx VOC NOx VOC NOx VOC NOx VOC NOx VOC NOx

San Joaquin 13.9 39.9 12.1 34.7 10.1 27.8 8.6 21.3 6.3 12.7 6.3 11.9

Stanislaus 10.5 26.7 9.0 22.3 7.5 17.2 6.5 13.4 4.9 8.0 4.6 7. 1

Merced 7.4 35.5 6.2 28.8 5.1 22.3 4.2 17.1 2.9 9.9 2.8 9.0

Madera 4.5 14.6 3.7 12.2 3.1 9.8 2.6 7.8 1.9 4.8 1.9 4.4

Fresno 18.6 58.5 15.5 47.9 12.9 37.2 11.1 29.1 8.0 16.9 7. 8 15.7

Tulare 10.5 23.4 9.2 20.9 7.7 16.6 6.7 13.1 5.2 8.4 4.8 7. 4

Kings 3.9 18.3 3.4 15.9 2.8 12.3 2.3 9.4 1.7 5.3 1.6 4.7

Kern (SJV) 18.1 93.9 15.7 79.4 13.5 64.1 11.6 49.5 8.5 28.4 8. 1 24.8

1 All emissions are expressed as summer tons/day, and were derived using EMFAC2007 (November 1, 2007) wi th updated vehicle population and vehicle miles travel ed data where available. The budget was establishe d by taking the EMFAC results, subtracting by County, emission redu ctions from District and ARB control measures and r ounding up to the nearest tenth if the hundredths place was “1” o r higher. See Appendix C for detailed documentatio n supporting the conformity emission budget development.

The MPOs and their member jurisdictions have adopte d Reasonably Available Control Measures (RACM) affecting motor vehicle use in the Valley. Three sets of RACM have been adopted in the past five years for the followi ng District-adopted air quality plans: (1)

The 2002/2005 Amended Rate of Progress Plan for San Joa quin Valley Ozone; (2) The Amended 2003 PM10 Plan (as amended on December 20, 2003); and (3 ) The 2004

EOADP. The transportation RACM for the 2003 PM10 Plan provide for the reduction of NOx and implementation of these measures is underwa y. For the 2007 Ozone Plan , the Valley MPOs drafted the local RACM approach and doc umentation regarding such implementation has been transmitted for interagency consultation. Additionally, the District reviews all applicable city and county pla n updates, RTP amendments, FTIP amendments, and hot-spot analyses to ensure that th ey conform with District plans.

7.2.3 Congestion Mitigation Air Quality (CMAQ) Prog ram The MPOs administer the CMAQ program. The purpose of the CMAQ program is to fund transportation projects or programs that will contr ibute to attainment or maintenance of the NAAQS for ozone, carbon monoxide (CO), and PM. While all CMAQ funding must go to transportation-related projects that demonstrate an air quality benefit, the eight Valley MPOs currently have different criteria and processe s for allocating funding to eligible jurisdictions.

In addition to the local RACM approach, the Valley MPOs are voluntarily developing a standardized process across the Valley for distribu ting 20 percent of the CMAQ funds to projects that meet a minimum cost-effectiveness beg inning in FY2011. This policy will focus on achieving the most cost-effective emission reductions, while maintaining flexibility to meet local needs. The policy is sch eduled to be implemented in FY 2011 because the current federally approved 2007 Federal Transportation Improvement Programs (FTIPs) have committed CMAQ funds through FY 2009 and in some cases, regional commitments continue through FY 2010. In addition, the current CMAQ programming assists in implementing approved local RACM (Amended 2003 PM-10 Plan) that are currently committed through 2010. D ue to changes in project costs and technology over time, the MPOs will revisit the min imum cost-effectiveness standard, asSection 7 – Federal, State & Local Controls 57

well as policy feasibility. A periodic review of t he policy is necessary due to potential changes in federal transportation legislation, appo rtionments, and project eligibility.

7.3 Summary of Federal, State & Local Controls In order to meet the 8-hour ozone NAAQS, consistent with the 2007 Ozone Plan, the District requires the collaboration of federal, sta te, regional, and local agencies. In light of the fact that mobile source emissions make up major ity of the Valley’s ozone precursor inventory, significant dependence is place on those agencies that regulate, monitor and affect transportation and vehicular movement and op eration.

Significant emissions reductions will be realized t hrough future state regulations for cleaner in-use heavy-duty trucks and off-road equip ment. Additionally, with anticipated growth in population and vehicle miles traveled, as shown in Section 2 of this review, working closely with the Valley MPOs and local juri sdictions will be critical for minimizing

automobile emissions reductions.

Such significant anticipated emissions reductions f rom mobile sources support the District’s analysis in Section 2 of this review, th at there are still significant reductions to be had in the Valley, thus ensuring ozone attainmen t by or before the 2023 deadline.58 SJVAPCD 2010 Ozone Mid-Course Review This Page Intentionally Blank