Proposed Draft: May 2010 

2010 Ozone 

Mid-Course Review
San Joaquin Valley Unified Air Pollution Control District

1990 E. Gettysburg Avenue 

Fresno, California 93726 

(559) 230-6100 

www.valleyair.org
Executive Summary i 

2010 Ozone Mid-Course Review 

Executive Summary 

The San Joaquin Valley’s surrounding mountains, stagnant weather patterns, and hot 

summers provide the ideal conditions for ozone formation. However, despite this 

uniquely difficult topography and meteorology, the San Joaquin Valley Air Pollution 

Control District (District) has a history of successfully developing and implementing 

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

In order to achieve these successes, the District developed 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 computer modeling, extensive 

public input, which included over 15 workshops and Town Hall Meetings involving over 

300 Valley residents, and extensive research into all feasible control options. Each plan 

included a comprehensive and exhaustive list of regulatory and incentive-based 

measures to reduce emissions of ozone and particulate 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 implementation of the Confined Animal 

Facilities Rule (4570), Phase II of the Stationary Internal Combustion Engines Rule 

(4702), Stationary Gas Turbines Rule (4703), and multiple 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 per 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 future advancements in pollution control 

technologies and increases in state and federal funding 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 while minimizing socioeconomic 

impacts. The ISR rule requires developers of new development projects to reduce 

emissions during both the construction and operational phases of the project. The 

District works closely with developers to maximize on-site emissions reductions at the 

proposed developments; however, if developers are not able to fully mitigate required 
ii SJVAPCD 2010 Ozone Mid-Course Review 

reductions through on-site measures, fees may be collected to fund off-site emission 

reduction projects. To date, the District has spent approximately $2 million in ISR fees to 

achieve over 1,172 tons of nitrogen oxides (NOx) emissions reductions and 43 tons of 

particulate matter (PM) emission reductions. 

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

to obtain reductions that would otherwise not be cost-effective for industry or are outside 

the District’s regulatory authority. Over the twelve 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, but 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 reductions could be used to reduce the 

“black box” emission reduction commitment. 

The District’s development and implementation of innovative strategies and outreach 

programs such as the Healthy Air Living Program, Fast 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 improved air quality. While 

implementing and fostering these activities is 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 

given the appropriate information and valuable decision-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 District and the Valley. 

The District has aggressively promoted technology advancement strategies. The 

recently approved Technology Advancement Program (TAP) will help ensure a 

comprehensive and collaborative approach to involving 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 progress that the District has made 

towards attaining the 1997 8-hour ozone national ambient 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 implementation 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 attainment 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 reductions 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 that decreasing trends in ozone 
Executive Summary iii 

concentrations are a result of successful regulatory and voluntary emissions reductions 

programs, not simply favorable weather conditions. Through District efforts, the Valley 

continues to be on-track to reach attainment of both the 1-hour and 8-hour ozone NAAQS 

by or before the applicable attainment deadlines. 

The path towards attainment is being further accelerated by Valley industry and municipal 

investments in cleaner technologies and emissions reductions implemented at the state 

and local level. These included over 20 regulations developed by the California Air 

Resources Board (ARB) in the last 3 years, numerous transportation control measures 

implemented by the metropolitan planning organizations, 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 improve as recent regulations are fully 

implemented, new control technologies are developed, and increased partnership 

between government and private entities occurs through programs such as Healthy Air 

Living, the Fast Track Action Plan, Regional Energy Efficiency Strategy, and the 

Technology Advancement Program. The District’s past 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 for particulate matter with an 

aerodynamic diameter of 2.5 microns or less (PM2.5) from 60 micrograms per cubic 

meter (μg/m3

) to 35 μg/m3. These two changes trigger a requirement for the District to 

develop new attainment demonstration plans for 8-hour ozone and PM2.5 in the 2013 

timeframe, which may include many of the regulations, incentive measures, and 

innovative strategies included in our current ozone plans. The achievements highlighted 

in this 2010 Ozone Midcourse Review, particularly for NOx, which is a precursor to both 

ozone and PM2.5, will assist the District in meeting these new, more stringent standards. 

Building upon the momentum for reductions from innovative strategies, new technologies, 

and partnerships with industry and the public the Valley can all look forward to a future of 

improved health and quality of life for Valley residents 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 Blank 
Table 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 ......................................................14

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 Traveled................................................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 Controls...........................................25

3.2 Feasibility Studies........................................................................................................28

3.2.1 Internal Combustion Engine (ICE) Electrification/Pump 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 Mitigation ...................................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 & Innovation 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 Incentive Programs...................................42

5.4 Summary of Incentive Program Success .....................................................................43
vi 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 ...............................................................57
Section 1 – Background & Summary 1 

Section 1 - Background and Summary 

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

Ozone Mid-Course Review (MCR) to demonstrate to the United States Environmental 

Protection Agency (EPA) that the District has met its obligations under the Federal Clean 

Air Act (CAA), as amended in 1999, for progress towards 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, and 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 reduced ozone precursors as seen in the 

continued downward trend of ambient ozone concentration levels and that the District is 

on track towards meeting attainment of the ozone NAAQS by the applicable attainment 

dates. 

Despite the fact that the EPA revoked the 1-hour ozone 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 classification and associated attainment 

dates of November 15, 2010 and end-of-year (EOY) 2023, 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, respectively. In developing the 

attainment plans for these ozone NAAQS, the District utilized photochemical modeling, 

air quality trend analysis, and other corroborating evidence to demonstrate that adopted, 

mandated, and voluntary control measures and additional 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 effectiveness of the groundbreaking rules, such 

as Indirect Source Review, Confined Animal Facilities, wine fermentation, and industrial 

combustion equipment, the California Air Resource Board (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 measures 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, if the prior year shows clean air quality 

data. This provision allows for a nonattainment area 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 than typical number of wildfires, 

meteorological patterns, and/or other events. In order to receive this one-year extension 

an air district must demonstrate to EPA that the previous year’s ozone levels meet the 1-

hour NAAQS in accordance with the implementation rule. 

The demonstration of attainment for both the 1-hour and 8-hour ozone NAAQS takes into 

account the significant natural challenges in the Valley, which are unmatched in any other 

region of the nation. While the Valley is one of the 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 and 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 accumulate within the Valley. The satellite 

photograph in Figure 1-1 demonstrates the manifestation of these significant natural 

challenges during the winter months; the trapped air layer not only includes fog, but 

undispersed pollutants. In the extremely hot summer months, the Valley is often capped 

with a temperature inversion layer that further traps 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 modeling the potential economic benefits 

of reductions in ambient ozone exposure provides decision makers and the public with 

valuable information for finding the critical balance that regulatory agencies such as the 

District must maintain between public health protection and economic viability. 

Additionally, decision makers and the public must have 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 documents the physical effects of ozone 

inhalation on humans. These studies have consistently shown that ozone can lead to 

inflammation and irritation of airway tissue. Breathing ozone can also reduce lung 

function and inflame lung epithelial lining. Symptoms and responses to ozone exposure 

vary widely among individuals. Typical symptoms include 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 respiratory systems are still 

developing, they are more susceptible to air pollutants. 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 outdoors.1

 Ground-level ozone is 

highest in the summertime, when children spend much of their day outdoors, thus 

disproportionately increasing their ozone risk relative 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 impacted as well. 

Ozone in sufficient concentrations increases the permeability, or “leakiness” of lung cells, 

making them more susceptible to environmental toxins and infection caused by 

microorganisms such as viruses and bacteria. In epidemiological studies, ozone 

exposure has been associated with an increase in hospital admissions and emergency 

room visits, particularly for pulmonary trauma, such as asthma and chronic obstructive 

pulmonary disease (COPD). Elevated ozone exposure has also been shown to be 

positively associated with premature death from respiratory disease in a recent study of 

448,850 subjects in 96 U.S. cities.2 Equally significant, a study of over 6,000 California 

births found that elevated ozone exposure during pregnancy 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 attacks, fewer cases of bronchitis, and 

fewer hospital admissions. 

 

1

 Peters, John, et al. (2004) Epidemiological Investigation 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. Margolis, 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 hospitalization and related health care costs as well as the Value of a 

Statistical Life (VSL). The VSL is an economic estimate of the social value of premature death that is used to guide 

policy makers in making public investments in public 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 Analysis Program (BenMAP) to predict 

the avoided costs of respiratory emergency room visits, respiratory hospital admissions, 

school days lost, acute respiratory symptoms, decreased worker productivity, and 

premature mortality as a result of reductions in ambient 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 District’s and State’s strategies are 

resulting in emissions reductions and air quality improvement needed to attain the 

revoked 1-hour ozone NAAQS and will result in the Valley’s attainment of the 1997 8-

hour ozone NAAQS by or before the 2023 attainment deadline. As a result of 

investments in cleaner technologies made by Valley businesses, municipalities, and 

residents, combined with emissions reductions implemented at the state and local level 

for mobile sources, the Valley appears to be on-track, in spite of anticipated population 

growth and an associated increase in vehicle miles traveled in the Valley. 

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

Plan, has achieved more emissions reductions than originally 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 proactive deployment of cleaner 

technologies and innovative control measures. To this 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 attainment deadline will require having 

no 1-hour ozone exceedances throughout the 2010 summer ozone season. I 

exceedances to occur, the District is prepared to initiate 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 determine if the Valley is “on-track” to 

achieve attainment of the 1-hour and 8-hour ozone NAAQS by their respective attainment 

deadlines. These analyses show that the District has made considerable progress since 

the CAA was amended in 1990 toward significant reductions in ozone precursor 

emissions and overall ozone concentrations. The degree of progress is particularly 

noteworthy since significant emission reductions have occurred despite concurrent 

population growth and an increase in vehicle miles traveled (VMT) within the Valley. 

Despite significant regulatory and voluntary successes 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 experienced a high number of forest fires, 

which because of the concurrent meteorological conditions, 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 stagnant 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, especially 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 exclusion of some of these exceedances 

from consideration in attainment determinations, but only for exceedances that resulted in 

multiple air districts. The District submitted Exceptional Event documentation to EPA for 

exclusion of some exceedances caused by wildfires that predominantly affected the 

Valley and thus were not included in the ARB submittal. 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, resulting in significant reductions in 

both volatile organic compounds (VOC) and oxides of nitrogen (NOx) emissions. These 

reductions will continue to grow through 2012 and beyond. Figures 2-1 and 2-2 show 

that anthropogenic VOC and NOx emissions are expected to decline by 43 percent and 

41 percent, respectively, by 2012 from 1990 emission 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 household water heater; stationary sources, 

or those that are not mobile, but large enough to be tracked individually, such as a power 

plant; on-road mobile sources, or those that operate predominantly on roads such as 

automobiles; and “mobile other,” or those mobile sources 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

700

Emissions (Annual Average tons/day)

1990 1999 2012

Figure 2-1 Valley VOC Planning Emission Projections

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

900

Emissions (Annual Average tons/day)

1990 1999 2012

Figure 2-2 Valley NOx Planning Emission Projections

Stationary Area On-Road Mobile Other

Additional strategies at the District and State level will provide substantial further 

emissions reductions after 2010. For example, on-road 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 these projections are based on the 

current statewide mobile source rules, ARB is considering 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 the 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 scheduled for 2010 through 2011 until 

2012, there will be no effect on the reductions ultimately projected for 2014. Such 

relaxation of compliance timelines will also give much needed relief to two industries that 

are severely affected by the current economic condition, while acknowledging reductions 

resulting from decreased equipment use during the economic downturn. 

2.2 Air Quality Trends 

The current ozone monitoring network consists of the 22 sites mapped in Figure 2-3. 

This monitoring network is jointly maintained by the District, ARB, and the National Forest 

Service. 

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

Ozone levels over the period of record have improved dramatically, corresponding to the 

significant decrease in ozone precursor emissions discussed above. The decrease in 

●

●

●

●

●

●

●

●

●

● ●

● ●

●

●

●

●

●

● ● ●

●

●

● ●

●

● ●

●

●

●

●

●

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 and 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 is achieved when the highest 

design value for all monitors in an area does not exceed 125 and 85 parts per billion 

(ppb), respectively. For the 1-hour ozone NAAQS, the design value at each monitor site 

is defined as the 4th highest daily maximum ozone concentration measured over a 3-year 

calendar period. Whereas, for the current 8-hour ozone NAAQS, the design value at 

each monitor site is defined as the average of each year’s 4th 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 design 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, the trend of design values data points was 

extrapolated by applying a best-fit line to the data, which is represented in Figure 2-5 and 

Figure 2-6 as a solid black line. 

The interval of normal meteorological fluctuation is represented as the residual, or 

difference between the expected value and the observed value. This difference is “added 

to” or “subtracted from” the trend line to represent the upper and lower residual, 

respectively, and is represented by the thinner dashed lines parallel to the trend line in 

Figure 2-5 and Figure 2.6. These residual lines represent the maximum and minimum 

design values for a year after considering meteorological fluctuations. The preliminary 
Section 3 – Regulatory Control Measures 9 

2009 1-hr ozone design value falls within these boundaries, 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 the 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 to determine attainment of the standard, 

if the District does not receive approval for the Exceptional Events in 2008, it may not be 

feasible to demonstrate attainment in 2010. In such case, the District would submit and 

Attainment Demonstration Extension request to EPA for 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 Value (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

Year

1-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 value and the observed value.

Of important consideration is the significant decrease in ozone design values measured 

from 2004 to 2008. This increased rate of change coincides with implementation of the 

EOADP and 2007 Ozone Plan, both of which have resulted in significant emissions 

reductions over the last four years. 
10 SJVAPCD 2010 Ozone Mid-Course Review 

Figure 2-6 Trends of Maximum 8-hr Ozone Design Value (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

Year

8-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 value and the observed value.

As the District continues the aggressive implementation 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 that 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 design value trends between 2004 and 

2008, attaining the appropriate design values by the attainment deadline is possible, yet 

will require aggressive implementation of voluntary programs and regulatory controls to 

further reduce emissions. Using the 2004 through 2008 trend line, as indicated by the 

heavy dashed trend line in Figure 2-6, the 8-hour design 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 occurrence of an exceedance day, it is the 

actual number of exceedance days within a three-year 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 one 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 recorded as measured for 1-hour and 

8-hour ozone for each year from 1999 through 2009 was 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 from 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 submitting a Clean Data Finding for the 

three years prior to attainment. If the District were to receive a one- to two-year 

extension, the requirement for making the Clean Data 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 subsequent 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 the 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 innovative strategies, new clean-air 

technology made available for industrial use, and meteorological conditions. The trend 

lines, shown in heavy solid and dashed lines in Figure 2-7, indicate that compliance with 

the 8-hour ozone NAAQS is achievable prior to the 2023 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

160

1999200020012002200320042005200620072008200920102011201220132014201520162017201820192020202120222023

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 reached when there are no more than 

three exceedances within a three-year period. While there were three exceedances in 

2009, there were 19 exceedances in 2008, most of which 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 this case, the District would request an 

 

5

 The higher than expected number of exceedances shown in 2008 is likely attributable to an unusually high frequency of wildfires that 

occurred during June and July of 2008 in Central California. In addition to particulate matter and carbon monoxide, wildfires release 

significant NOx and hydrocarbons creating excessive ground-level ozone even in areas far away from traditional urban ozone 

sources. ARB submitted Exceptional Event documentation to EPA on behalf of all California air districts requesting exclusion of some 

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

extension to 2011 from EPA. In 2012 the District would be able to request that EPA 

make a Clean Data Finding based on 2009 through 2011 data. 

As regulatory control measures and innovative strategies continue to lower Valley ozone 

levels, meteorology and wildfires have a proportionately 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 shown in the reductions of ozone and 

ozone precursor emissions, the meteorology and wildfires may create a stronger 

possibility for the occurrence of a 1-hour ozone exceedance. Given the potential for 1-

hour ozone exceedances over the next two summer ozone seasons, the District is 

prepared to implement a Section 185 nonattainment fee program, or implement an 

alternative equivalent program to offset fees imposed by the federal requirement, if 

required. 

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

The Expected Peak Day Concentration (EPDC) is useful for tracking ambient air quality 

progress at individual monitoring locations. The EPDC is calculated for each monitor 

location using daily maximum 8-hour ozone observations for a three-year period, which 

includes the summary year and the two years immediately 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 concentrations. The fitted distribution is used to 

analytically determine the peak concentration expected to occur once per year, on 

average. This robust statistical calculation is relatively 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 1994 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 lowering of EPDC values6

. In all 

counties except San Joaquin and Kings, the year 2008 does not fall along the downward 

trend line. As indicated previously, in 2008 the Valley was affected by an unusually large 

number of wildfires that plagued the state of California together with a significant number 

of days in which inversion layers or other meteorological conditions prevented pollutant 

dispersion. 

The steady improvement in EPDC values in part represents regulatory and nonregulatory efforts to reduce emissions of ozone precursors. As with the design value 

data shown previously in this section, the EPDC data from the counties of Madera, 

Fresno, Tulare, Kings, and Kern all show marked improvements in EPDC values starting 

in the year 2004, which coincides with the implementation of the District’s strategies to 

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

EOADP. Continued improvement coincides with implementation 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 plan adoption. 

 

6

 Merced County is not included in the EPDC analysis because of the lack of valid data for the years 2006 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 2008

ppm

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 2008

ppm

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 Year

ppm

San Joaquin County 

0.08

0.09

0.1

0.11

0.12

0.13

0.14

1994 1996 1998 2000 2002 2004 2006 2008

ppm

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 St
14 SJVAPCD 2010 Ozone Mid-Course Review 

2.3 Evaluation of Ozone Trends Adjusted for Weather 

Analysis to this point has relied on direct observations of ozone. However, since ozone 

concentrations are highly dependent on weather conditions, long-term weather patterns, 

such as shorter than average winter seasons and dryer than normal winters, make 

interpretation of ozone trends challenging. The changing distribution of weather 

parameters, such as temperature, wind, ultraviolet radiation, and vertical stability, result 

in seasons with greater or lesser potentials to produce ozone than an “average” season. 

Without considering the effect of meteorology on ozone concentrations, it is difficult to 

determine if changes in observed ozone concentrations are due to effective control 

strategies or meteorological fluctuations. 

District analysis indicates that long-term fluctuations in weather patterns create significant 

variation in annual season-average ozone concentrations. These large variations in 

seasonal ozone averages attributed to weather indicate 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-adjusted ozone concentrations have 

steadily decreased, indicating that the observed long-term ozone improvement trend is 

likely attributable to emission reductions and not weather variations. Further analysis 

indicates that the overall weather-adjusted ozone trend is nearly identical to, but 

decreases slightly faster than, the overall unadjusted trend. This finding indicates that 

ozone trend analysis completed throughout this report is valid and potentially 

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

detail. 

2.3.1 Meteorological Adjusted Ozone Trend Methodology 

EPA developed a statistical method to account for the weather-related variability of 

seasonal ozone concentrations7

. This method compares the observed seasonal average 

daily 1-hour and 8-hour average ozone concentrations to the same parameters with the 

influence of weather removed. Since this method uses 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, the 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 District 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 solar radiation, were used to develop 

quantitative relationships between ozone and meteorology for monitoring sites in the 

Valley. Results from this quantitative relationship were compared against observed air 

quality. The weather-adjusted ozone trend can be used to evaluate changes in precursor 

emissions attributable to control measures. The sites 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 representative 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 Interpretation 

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 concentrations anticipated under typical 

weather conditions and serves as a more accurate method 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 and weather-adjusted concentrations, 

respectively. 

When the unadjusted value is greater than the meteorologically adjusted value, the 

seasonally averaged observed concentrations were higher due to weather. When the 

unadjusted value line is less than the meteorologically adjusted value, the seasonally 

averaged observed concentrations were lower due to weather. When the adjusted value 

closely approximates the unadjusted value, the summer was near the statistical average. 

Figures 2-9 through 2-22 indicate that the summer of 2002 was near the statistical 

average for most sites, since observations are closely approximated by adjustments for 

weather. In addition, the significant increase in ozone 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 sites. In addition, although much of 

the 2008 summer observations are attributable to weather, increases in ozone 

concentrations adjusted for weather can be attributed to the influence of northern and 

central California wildfire emissions during the 2008 ozone season. 

After being adjusted for weather, all sites evaluated (Figures 2-9 through 2-22) show a 

decrease in 1-hr and 8-hr average ozone concentrations 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 improvements. In addition, since the 

overall weather-adjusted ozone trend is nearly identical to, but slightly steeper than, the 

overall unadjusted trend, analysis completed throughout 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 Trends 
Section 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 Trends 
18 SJVAPCD 2010 Ozone Mid-Course Review 

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

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

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

Figure 2-16: Arvin, 8-hr Ozone Trends 

 
20 SJVAPCD 2010 Ozone Mid-Course Review 

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

Figure 2-18: Fresno-First St, 8-hr Ozone Trends

 
Section 3 – Regulatory Control Measures 21 

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

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

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

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

2.4 Growth Trends in Population & Vehicle Miles Traveled 

The significant decline in emissions and ozone levels over the past several decades has 

occurred during a period of overall population growth and increased vehicle miles 

traveled (VMT) in California and the Valley. 

As shown in Figure 2-23, population in the Valley has increased by 26 percent since 

1999, whereas the population in the State only increased 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 see 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%

19992001200320052007200920112013201520172019

Growth Relative to 1999

CA Valley

 Source: ARB CEPAM:2009 Almanac – Population and Vehicle Trends Tool 

A similar trend holds true for VMT in California and 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 2010 and 2020, the projected VMT 

increase for California is 15 percent and 25 percent for the Valley. 

Figure 2-24 Estimated Growth in Vehicle Miles Traveled

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

19992001200320052007200920112013201520172019

Growth Relative to 1999

CA Valley

 Source: ARB CEPAM:2009 Almanac – Population and Vehicle Trends Tool 
24 SJVAPCD 2010 Ozone Mid-Course Review 

Based on the growth in population and the associated increase in VMT, one would 

expect a related significant percent increase in ozone. However, as shown throughout 

this review, there has been a significant decrease, suggesting that control strategies have 

both mitigated the increase in ozone attributable to population growth and decreased the 

baseline ozone levels. 

2.5 Summary of Air Quality and Regional Growth Trends 

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 ozone 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 grant 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 reductions of 

ozone precursor emissions than was committed to at the time of each plan’s adoption. 

This is consistent with the improving air quality trends 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 adopted 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 committed 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 new information is obtained regarding 

the emission inventory, the rule baseline, or inventory, may be different from the plan 

baseline or inventory. The reductions calculated during the rule development process 

are calculated base on the rule baseline. Thus, evaluation of rule effectiveness with 

regard to emissions reductions requires the conversion of the rule reductions to “SIP 

Currency.” All reductions in Tables 3-1 and 3-2 are stated in SIP Currency and are 

calculated as follows: 

Emission Reductionsin SIP Currancy Plan Baseline

Rule Baseline

Rule Reductions

= ×
26 SJVAPCD 2010 Ozone Mid-Course Review 

Table 3-1 Completed 1-hour Ozone Plan Control Measures 

Plan 

Commitment 

(tons/day) 

Actual 

Reductions 

(tons/day) 

Additional 

Reductions 

Control Measure (tons/day) 

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 and controls, in tons per day, rounded to the nearest then of a ton per day 
Section 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 estimated 

emission reductions based on the adopted rule, and any emission reductions that were 

surplus to the plan commitments. The District adopted 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 based 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 developed. During rule development, the 

District sometimes found that technologies had advanced 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 control technology was not applicable to the 

entire source category and fewer reductions were realized from some of the control 

measure projects. In 2014, the currently adopted control 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 will be used to offset any 

shortfalls that may occur in future rule development projects and will be applied towards 

the additional “Black Box” reductions required by the 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 studies for potential control measures to 

evaluate opportunities for additional emissions reductions. 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 program, or advocacy action; in some cases, 

the emissions inventory may prove to be too small or 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 for 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 commitment, 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 to 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 emissions 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 subsequent rulemaking. No Plan 

control measure commitment. 
Section 3 – Regulatory Control Measures 29 

• Reviewing best management practices and technologies that likely have the 

potential to achieve cost-effective emission reductions from the sources 

considered by the feasibility study; 

• Reviewing regulatory, incentive, and advocacy options for achieving emission 

reductions from the sources being evaluated by the feasibility study; 

• Providing details to the public of the District’s intended actions for this source 

category based on information acquired by staff during the feasibility process. 

This may be at a rule development workshop, stakeholder workshop, in a 

document or notice published on the internet, or through any other means 

deemed appropriate by staff considering the applicability and results of the 

feasibility study. 

District staff may also research other controls measures that are not identified in an 

adopted attainment plan, but which are suggested after the plan is finalized. These 

studies may include application of reasonably available control technology or 

management practices for current or new sources where emission reductions are costeffective via a rule, incentive program, or other strategy. 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, cost data, economic impacts, and other 

feedback on the draft rule prior to seeking Governing 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 the additional reductions required by the 

2007 Ozone Plan “black box.” Specifically the “black box” requires that regulatory or nonregulatory measures shall be put in place by the end 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 initiated all 

feasibility studies that were scheduled by 2009. The 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 Studies 
30 SJVAPCD 2010 Ozone Mid-Course Review 

Table 3-4 Planned Stationary Source Feasibility Study 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) 2012

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) Electrification/Pump Efficiency Incentives 

The 2007 Ozone Plan committed the District to conduct a feasibility study for emissions 

reductions from expanding regulation of incentive programs for Reciprocating Internal 

Combustion Engines (ICE). Businesses and agencies that use internal combustion 

engines include, but are not limited to, schools and universities, dairies, agricultural 

production, petroleum refiners, food processing, public water districts, and manufacturing. 

Many compression-ignited engines are used in agricultural production for irrigation and in 

other businesses as emergency engines to provide backup power when electric service 

is interrupted. 

District staff evaluated rules from other air districts, including South Coast Air Quality 

Management District, and the BACT database to identify potential options. Staff 

reviewed the District permit and grant databases to estimate the number of reciprocating 

internal combustion engines over 50 horsepower operating in the Valley and sorted these 

by fuel type (diesel, natural gas, or electric). Staff 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 obtaining cost-effective emissions 

reductions from this source category are good. Additionally, many agricultural industry 

stakeholders including the California Cotton Ginners 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 information 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 feasibility study to 

determine if emissions from wildfires, prescribed burns, and hazard reductions burns 

could be further reduced to improve air quality. In May 2009, District staff completed this 

feasibility study, after consulting stakeholders, and found that the enormous and untimely 

emissions produced by wildfires can be reduced by increasing and modifying prescribed 

burning, pile burning, and hazard reduction burning practices. The feasibility study 

determined that in order to prevent wildfire emissions, the following actions would be 

required: 1) increase legislative action for more prescribed burning resources, implement 

policy modifications to raise the priority of air quality-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 amendment to the District’s 2009 

Legislative Platform to include a recommendation for Curbing Wildfires and the 

Associated Adverse Public Health Impacts. The District’s 2010 Legislative Platform 

continues to include a recommendation for Curbing Wildfires and the Associated Adverse 

Public Health Impact. Furthermore, during the wildfire and prescribed-burn season, the 

District participates in daily coordination calls with multiple agencies, including land 

management associations, as needed. The District has also developed brochures and 

hosts a webpage to educate the public on hazard-reduction burning, issues daily burn 

forecasts, and provides the public with a phone number to obtain additional information 

about hazard-reduction burning and prescribed burning 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 (QAB), is defined as agricultural material, 

which may be considered for on-site open burning, but could be diverted to a biomass 

power plant for use as fuel, thus reducing significant emissions inherent in the open burn 

process. Such materials include various pruning material, orchard and vineyard removal 

material, and rice, wheat, and barley straw. Agricultural material burned in combustors at 

a biomass power plant is used to produce steam, which then spins turbines to generate 

electricity. Burning of agricultural material is on option for compliance with District Rule 

4103. Additionally, for the most part, such electricity is sold to utility companies to meet 

their renewable energy resource commitments as a part of the California Renewable 

Portfolio Standard (RPS) established by Senate Bill 1078. 

During the feasibility study process, District staff identified an opportunity to achieve 

emissions reductions from such QAB. The District study showed that approximately 

149,567 acres, equating to 483,316 tons of agricultural 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 2008, 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 least costly option for growers; however 

adherence to regulatory burn schedules sometimes prohibits efficient and timely removal 

of agricultural material. An alternative option for 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 facility, 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 agricultural fuel. In recent years, due to the 

economic downturn and resulting lack of available urban waste, the biomass power 

plants have increased the use of QAB as fuel. District 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 economic 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 development and implementation of an 

incentive program to increase the use of QAB as fuel 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 aware of any federal or state funding 

programs that are in the planning stages. While there 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 QAB 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 technology 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 study 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 4723 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 identified 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 the emission inventory for this source 

category. The District has reviewed the permit database, acquired information from the 

regional water board, acquired information from the California Division of Oil, Gas, and 

Geothermal Resources, worked with ARB to obtain information from survey results, and 
Section 3 – Regulatory Control Measures 33 

spoken with industry representatives to estimate the 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 information source. The District is 

also evaluating the cost and impact of various control options and considering voluntary 

options to reduce emissions. At this time it appears that the potential for VOC emission 

reductions may be low considering the small inventory 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 Study to evaluate 

the potential of VOC emissions reductions through the prevention of oil leaks in 

production of heavy crude oil in Valley. 

District staff analyzed the costs and cost-effectiveness of controlling leaks from heavy oil 

components by requiring periodic inspections of the components. Additionally, staff 

refined the inventory with information obtained from the state and crude oil and natural 

gas stakeholders. Based on the analysis District staff is not recommending a VOC rule 

project for this source category at this time, citing that the potential for VOC emission 

reductions was limited and the cost effectiveness for 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 evaluating the feasibility of a 

control measure. However, ARB does have the authority 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 evaluating this source category as a 

greenhouse gas reduction measure for meeting AB32 reduction goals. Any actions to 

reduce greenhouse gas from heavy crude oil components will have a co-benefit of 

reducing VOC emissions. The District will monitor ARB’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 emissions 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 “units”) 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, coal, municipal solid wastes, tires, 

biomass wastes, urban and construction wood wastes, or any combination thereof. 

The District’s analysis showed that it may be technologically feasible to control NOx 

emissions with Selective Catalytic Reduction (SCR) or hybrid SNCR/SCR. Additionally, 

there are boilers that are operating at emission levels 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 filters/baghouses and/or electrostatic 

precipitators, which are considered as Best Available Control Technology (BACT) for this 

source category. The units are already operating lime 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 reductions, a rulemaking project will be 

scheduled for the next available opportunity to consider additional controls and lower 

limits for solid fuel fired boilers, steam generators, and process heaters, in addition to 

addressing EPA concerns regarding the current District Rule 4352. 

3.2.7 Small Boilers 

The 2007 Ozone Plan committed the District to conduct a Feasibility Study to re-evaluate 

the potential of further NOx emissions reductions from boilers, steam generators, and 

process heaters rated at 0.075 to less than 2.0 MMBtu/hr subject to District Rule 4308. 

Staff completed the Feasibility Study in 2009 and initiated a rule amendment project to 

establish more stringent NOx emissions limits for units running on PUC-qualified natural 

gas. The District Governing Board adopted Amended Rule 4308 on December 17, 2009. 

Amendments approved by the Board included elimination of the previous exemption for 

humidifiers, addition of an exemption for recreational vehicles, reduction of the emission 

limits for most categories, and adjustment to the compliance schedule for the rule. The 

rule achieved a 75 percent reduction in emissions from small boilers rated from 0.075 to 

less than 0.4 MMBtu/hr. The rule achieved an 85 percent 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 source category for boilers, steam 

generators, and process heaters rated at 0.075 to less than 2.0 MMBtu/hr, which takes 

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

than less than 0.4 MMBtu/hr. The cost effectiveness of this rule was estimated at $1,500 

to $2,000 per ton of NOx reduced for individual units. 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 efficiency units. 

3.3 Summary of Regulatory Control Measures 

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

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

the District identified additional emissions reductions 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 emissions 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 reducing emissions from stationary 

sources through District regulations, growth in area-wide and motor vehicle emissions 

has diminished the overall effect of such regulations. The past and expected increases in 

population and VMT, as shown in Section 2, add to the 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 were not achieving the necessary 

results to meet NAAQS attainment deadlines, the District sought to reduce such 

emissions indirectly. 

District Rule 9510, Indirect Source Review (ISR) spans the gap between regulatory 

control measures and incentive programs developed by the District for emissions 

reductions. ISR was developed from an emissions reduction 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 land development in the Valley. 

During the ISR process, District staff evaluate projects for baseline NOx and PM 

emissions and potential reductions based on construction, design, and ongoing 

operations. For emissions not mitigated on-site, Rule 9510 has an established fee 

schedule to account for any off-site emissions required 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 NOx and 1,692 tons of PM emissions 

have been reduced through on-site mitigation, either 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 achieve through on-site emission 

reduction measures. 

While the District has collected off-site mitigation fees, litigation against the District over 

the ISR Rule has delayed expenditure of the majority of funds. On June 27, 2006 a 

lawsuit was filed by various building industries challenging the validity of Rule 9510. On 

March 25, 2008, the Fresno County Superior Court ruled 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 portion of the rule on federal law grounds, 
36 SJVAPCD 2010 Ozone Mid-Course Review 

is pending before the Ninth Circuit Court of Appeals. 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 federal lawsuit. 

4.1 On-Site Emissions Reductions & Off-Site Emissions Mitigation 

ISR applies to new development projects that emit emissions of at least two tons of NOx 

or two tons of PM10 per year. The rule contains provisions exempting traditional 

stationary source projects that are subject to the District’s stationary source permitting 

requirements. Developers of projects subject to ISR must reduce emissions occurring 

during construction and operational phases of a development project. During 

construction, exhaust emissions of NOx and PM10 are to be reduced by 20 and 45 

percent, respectively. Construction exhaust emissions can be reduced through 

installation and use of aftermarket devices or through the use of construction equipment 

that is newer than the statewide average. Operational emissions of NOx and PM10 are 

to be reduced 33.3 and 50 percent, respectively, from the project baseline for 10 years. 

Operational emissions can be reduced through any combination 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 developer can pay an offsite mitigation fee to 

the District. One hundred percent of all offsite mitigation fees received by the District are 

to be used to fund emission reduction projects, achieving emission reductions on behalf 

the original project. 

In an effort to avoid mitigation fees, developers incorporate many air-friendly operational 

and design components into their proposals. At the time of initial construction, significant 

emissions reductions are garnered through the use of modern or retrofitted construction 

equipment. In planning for operational emissions reductions, 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 emissions reductions. 

4.2 Mitigation Fees for Incentives 

In light of the legal issues related to ISR, the majority 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 the Valley. The District collaborated with 

the Natural Resources Conservation Service (NRCS) to co-fund agricultural tractor 

replacement projects using $2 million of ISR off-site fees. Funds utilized by the NRCS 

were provided through the Environmental Quality Incentives Program (EQIP) 

Conservation Innovation Grants (b) [CIG (b)] portion of the 2008 U.S. Department of 

Agriculture Farm Bill. 

The District and NRCS combined funding to replace existing, in-use agricultural tractors 

equipped with uncontrolled (Tier 0) engines with new tractors equipped with Tier 3 or 

cleaner engines. Total funding provided by both agencies paid up to 70% of eligible 
Section 4 – Indirect Source Review 37 

tractor costs. In an effort to achieve maximum emissions 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 replaced with one new tractor. 

The following table summarizes the estimated lifetime 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 funds have been sequestered in light of 

litigation, thus anticipated emissions reductions are not yet realized. Recent legal 

decisions have the effect of releasing approximately $7 million for District use in 

emissions reductions projects. While the District anticipated a steady utilization of these 

funds for incentive programs, full implementation should result in intensified emissions 

reductions over the next few years and help to maintain the increased rate of reductions 

subsequent to 2005. Through established accountability measures, ISR ensures that the 

District will utilize off-site fees to fund quantifiable and enforceable off-site projects that 

reduce surplus emissions of NOx and PM10. 
38 SJVAPCD 2010 Ozone Mid-Course Review 

This Page Intentionally Blank
Section 5 – Incentive Programs 39 

Section 5 - Incentive Programs 

While the District’s regulatory control of stationary 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 by 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 developed other non-regulatory emissions 

reduction strategies to accelerate attainment of the 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 attainment of the 8-hour ozone NAAQS in the 

Valley. The “black box” contains those measures, including potential regulatory and nonregulatory measures identified in feasibility studies subsequent to attainment plan 

adoption, that incentivize voluntary reductions or utilization of newer technologies when 

not immediately economically feasible for a given source category. 

The District’s highly successful Emissions Reduction Incentive Program (ERIP) is one 

strategy that provides such non-regulatory emissions 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 projects that achieve emission reductions 

prior to or beyond reductions required from rules and regulations. Most importantly, 

incentives allow the District to reduce emissions from source categories outside of the 

District’s regulatory authority, as well as source categories where financial hardship 

would otherwise prevent traditional control strategies from being implemented. 

5.1 Ongoing Incentive Programs 

Since 1992, the District has gained significant experience in developing and 

implementing successful incentive programs. The funding 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 Engine Emission Reduction Incentive 

Program (Heavy-Duty Engine Program), the Reduce Motor Vehicle Emissions II 

(REMOVE II) Program, and Community Based Incentives. These overarching programs 

offer incentives to businesses, public agencies, and the general public for a wide variety 

of emissions reductions projects including the Lower Emission School Bus Program, the 

Burn Cleaner Wood Stove Change Out, and the Stationary Agricultural Irrigation Pump 

replacement program as opportunities to achieve cost-effective emission reductions 
40 SJVAPCD 2010 Ozone Mid-Course Review 

present themselves and funding becomes available, the District has been willing to 

develop new programs and new components for existing programs. 

The amount of funding currently available to the District for incentive-based programs is 

over $100 million per year. The primary sources for these funds are the expected 

revenues from the District’s Indirect Source Review Rule, voluntary development 

mitigation agreements, local DMV surcharge fees, the 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 Emission Reduction Program (Prop 1B) 

for the San Joaquin Valley. The Prop 1B program provides incentive funds to retrofit or 

replace diesel engines in heavy-duty trucks, locomotives, 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 of 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 awarded approximately $92 million in June 

2010 for eligible equipment projects. 

Table 5-1 identifies the individual incentive programs that the District has or is 

administering, including the total funding amount for each program, how many projects 

were funded for each program, and the applicable NOx 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 calculated 
Section 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 - 2009 

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 programs 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 emission 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 work 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 project 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 incentive funding opportunities. The 

following programs are currently in development: 

5.2.1 Technology Advancement Program (TAP) 

In addition to the traditional incentive programs that have been implemented, the 

District’s Governing Board recently adopted the Technology Advancement Program 

(TAP). The primary goal of TAP is to advance technology 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 the 
42 SJVAPCD 2010 Ozone Mid-Course Review 

procurement of incentive funding for research and new 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 areas of specific need in the Valley. 

5.2.2 Air Quality Action Center for Technology & Innovation for the Valley 

The District, in collaboration with Valley Universities, 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 resources to build regional capacity for 

research, technology demonstration projects, and expended emissions measurement 

and testing in the Valley. 

5.2.3 Energy Efficiency Funding Opportunities 

The District’s Fast Track Action Plan, which is discussed 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 efficiency and will be providing the lead role in 

the implementation of the California Energy Commission’s (CEC) Small Jurisdiction 

Energy Efficiency and Conservation Block Grant Program (EECBG). The EECBG will 

provide approximately $4 million to small cities and counties throughout the Valley for 

energy efficiency retrofit projects in jurisdictional facilities. Such projects include lighting 

replacements to energy efficient compact fluorescent bulbs, LED street light retrofits, 

heating ventilation and air conditioning system upgrades, 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 number of regional and large-scale grant 

applications that will benefit air quality in the hopes of bringing much-needed funds into 

the Valley. Most recently, the District has received 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 fund projects such as school bus 

replacement and retrofit, agricultural irrigation pump repowers, and the on-road heavy 

duty truck selective catalytic reduction (SCR) technology demonstration project. The 

District has also applied for funding through the Department of Energy (DOE), including 

funding available through the American Recovery and Reinvestment Act, the EPA’s 

Climate Showcase funding opportunity, and DERA Heavy-Duty On-Road replacements. 

5.3 State Implementation Plan Creditability for Incentive Programs 

Current federal policy limits the use of incentive-based emissions reductions to meet CAA 

goals in air quality plans. Projects in this category 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 adopted air quality plans, some level of SIP 

creditability must be achieved for emissions attained through its incentive program. The 

District is working closely with the EPA to identify 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 framework 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 already has the core elements that 

contribute to the creditability of emission reductions in the SIP. These elements include 

increased post-project monitoring, verification of emission reductions and comparison 

with predicted reductions, real-time reporting of emission reductions with associated 

preparation of annual reports, and development of program elements such as protocols 

in a transparent and open process. The District has continued to create and implement 

incentive programs in a manner consistent with these 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 ozone precursor emissions through its 

aggressive Emissions Reduction Incentive Program. Over the twelve years of active 

incentive program implementation NOx and VOC emissions have been reduced by 

62,078 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 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 processes, and increase applicant 

participation. 

The District’s incentive programs have not only proven to be a highly cost-effective 

method for improving Valley air quality, but have become a model for incentive programs 

throughout the state. In recent state audits, which included the Bureau of State Audits, 

ARB Carl Moyer Program, and State Department of Finance, the District was noted for its 

efficient, robust, and effective use of incentive grant funds in reducing air pollution. 

Because of this recognition, numerous other California air districts have approached the 

District to either assist with incentive fund administration 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 County, Antelope Valley, Mojave 

Dessert, Mariposa County, and Calaveras County air districts. 
44 SJVAPCD 2010 Ozone Mid-Course Review 

This Page Intentionally Blank 
Section 6 – Innovative Strategies 45 

Section 6 - Innovative Strategies 

The District’s ability to develop stringent, yet economically feasible stationary source 

regulations and secure much-needed incentive and grant 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 attainment 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 strategy. 

To date, the implementation of such innovative strategies has led to increased public 

awareness of air quality issues, increased public participation towards air pollution 

solutions, and improvement in air quality in the Valley. This broad spectrum of 

involvement will be critical in helping the District 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 individual and 

collective strategies that reduce emissions. The goal 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. Healthy Air 

Living has become the District’s hallmark program and 

now encompasses all regulatory and voluntary emissionreduction measures. The slogan, “Make One Change,”

and the colorful, distinctive Healthy Air Living logo brand 

all outreach materials and advertising. 

Although only recently implemented, Healthy Air Living has already produced several 

high-profile, high-participation campaigns, including 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 clean-air choices that work in their lives, 

and they will commit to healthier lifestyles. Healthy Air Living aims to reduce emissions 

through a variety of ways on both individual and organizational levels, including: reducing 

the number of vehicle miles traveled each day through the Valley; reducing emissions 

during peak smog episodes; reducing emissions created by equipment and processes; 

and encouraging higher energy efficiency and the development of cleaner energy 

sources. 

6.2 Fast Track Measures 

On June 21, 2007, the District Governing Board adopted 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 evolving technologies, market opportunities, 
46 SJVAPCD 2010 Ozone Mid-Course Review 

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

the 2023 federal deadline. 

The following sections describe the innovative strategies 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 Control Technology (RACT) and at least 

one generation of Best Available Retrofit Control Technology (BARCT) on virtually all of 

the stationary sources in the Valley. As the District continues to implement its clean air 

strategy, some industries have implemented fourth and 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 reductions, including past, current, and 

proposed control measures, there remains a significant need for additional reductions. 

Attaining the 8-hour ozone standard requires emission reductions of approximately 75 

percent from 2005 levels. Because of this need, the District has and will continue to seek 

to reduce emissions from source categories and industries that have been previously 

controlled, although continued generations of emissions 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 options that operators could use to 

comply when unable to utilize such advanced technologies. The specified emission 

reduction options would include control of the subject equipment, mitigation fees, 

specified offsite reductions, and alternative onsite approaches. All of these options would 

be well in excess of previously established RACT and BARCT levels. Each option will 

have adequate provisions to ensure reductions are surplus, enforceable, quantifiable, 

and permanent. During each rulemaking project, District staff will determine if benefits 

could be achieved through AERO provisions being incorporated into the rule. 

6.2.2 Alternative Energy 

The use of alternative sources of energy reduces and 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 energy sources, generally the combustion 

of fossil fuels. Potential alternative energy sources include, but are not limited to: landfill 

gas; VOC and methane from confined animal facilities; agricultural waste products such 

as prunings, rice stalks, and orchard removal materials; biosolids; VOC from oil and gas 

production plants and other industrial facilities that are incinerated using flares or thermal 

oxidizers; solar; and hydrogen fuel cells. 

The District has developed resources to promote alternative sources of energy, 

supported efforts promoting alternative energy, and aligned the District programs with 

initiatives that promote alternative energy, including utilizing ERIP funding for alternative 

fuel vehicles. Additionally, as part of the 2010 Legislative Platform the District committed 

to supporting legislation that provides additional biomass capacity utilizing agricultural 
Section 6 – Innovative Strategies 47 

materials and expanding net metering and feed in tariffs for the utilization of solar and 

other renewable sources of energy. 

6.2.3 Energy Conservation 

The District has taken several steps to increase energy 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 the District’s 2010 Legislative Platform, the 

Governing Board approved the District’s Regional Energy Efficiency Strategy (REES) in 

January 2010. The District’s proactive role as a regional 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, including 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 quality benefits of energy efficiency; 

identify regional barriers that have prevented maximum 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 leverage the maximum support, services, 

expertise, and funding for unlocking the energy efficiency potential; and develop a 

reliable and sustainable funding stream to incentivize energy efficiency and encourage 

development and utilization of new energy efficiency technologies. 

Currently the District is serving as a role model for other entities by evaluating their own 

energy efficiency and conservation practices. Through 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-cost energy conservation and waste 

minimization opportunities within its offices. Many of these measures can be readily 

applied to other businesses. The District is willing 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 activities 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 overall 20 percent and gross nonresidential electricity use can be reduced by 15 percent. Complexities in the import and 

export of electricity across regional boundaries will affect the ultimate realized reductions. 

Achieving such gross reductions across all economic sectors will require and effective 

and coordinated regional effort, one which the District is prepared to facilitate. 

6.2.4 Episodic & Regionally-Focused Controls 

Advances in real-time air quality measurement and meteorological forecasting have 

made it possible to apply regulatory controls in a more focused manner. Examples of this 

concept include the District’s Smoke Management Program and the “Check Before You 

Burn” Program that implements Rule 4901 (Wood Burning Fireplaces and Wood Burning 

Heaters). Both programs use real-time meteorological measurements and emissions 

estimates to determine if next-day conditions are conducive to violations of ambient air 
48 SJVAPCD 2010 Ozone Mid-Course Review 

quality standards. The District’s forecasters prepare and issue forecasts that can result 

in episodic and county-specific prohibitions on prescribed burning, agricultural burning, 

and residential fireplace burning. 

Banking on the success of these programs, the District believes that episodic and 

regionally focused controls could be used to “surgically” control emissions during the 

worst days of the ozone season. The District will consider episodic controls and 

regionally-focused controls during each rule development project in order to optimize the 

benefits of each measure. Some of the source categories that may also be evaluated for 

possible episodic/regional controls include: recreational vehicles, including dirt bikes and 

power boats; non-essential structural painting and related activities; non-essential 

through-truck traffic in urban areas; industrial activities amenable to postponement; 

diversion of heavy duty diesel truck traffic from Highway 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 use low-emission fleet vehicles and 

equipment, and to those that actively promote ridesharing programs. Contracts awarded 

to companies with “green” practices could also contain clauses that require participation 

in District Spare the Air activities. While the District does not have regulatory authority to 

require local government agencies to adopt these ordinances, 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 District will: 

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

counties; 

• Make Green Contracting an attractive option for contractors by awarding 

incentive funding for the retrofit of off-road construction 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 legislative 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, decreased greenhouse gas and criteria 

pollutant emissions, and improved organizational reputation. The District has achieved 

significant emissions reductions from encouraging fleet 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 temperatures 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 island mitigation and promote its 

adoption by cities and counties, including providing incentive funding to seed 

projects; 

• Encourage practices conducive to heat island mitigations through 

informational educational opportunities and incentives; 

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

and 

• Support research that adds certainty to the emission reduction potential or 

benefits of heat island mitigation programs. 

The District is currently working with the University of California at Davis on a project to 

assess the benefits of implementing heat island mitigation 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 and private matching funds 

required) to establish a high-speed train service linking Southern California, the Central 

Valley, and the San Francisco Bay Area. This project has the potential to dramatically 

reduce passenger car trips through the Valley, reduce emissions, and improve air quality. 

The California High Speed Rail Authority and partners are currently holding public 

meetings and workshops as they develop Environmental Impact Reports for each major 

section of the proposed railway.8 District staff will continue to participate in many of the 

meetings and workshops. 

6.2.9 Inland Ports and Short Sea Shipping 

These two Fast Tracks initiatives could provide a very large emission reduction, but 

would require significant additional infrastructure, for which the District is actively lobbying 

for federal and state infrastructure funding. Additionally 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 taken a leadership role, partnering with 

the Bay Area Air Quality Management District and the 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 committee, is currently working to use 

Proposition 1B funds to establish the most effective 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 funded by the state’s Proposition 1B 

 

8

 The annual report for this project can be found at

www.cahighspeedrail.ca.gov/news/CHSRAProgramSummaryReportJuly2009.pdf. 
50 SJVAPCD 2010 Ozone Mid-Course Review 

Goods Movement Emission Reduction Program. Following the close of the Year 1 

solicitation period (7/5/08-9/5/08), applications from 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 emission reductions that would be achieved 

by truck replacement, retrofits, and repowers. Notices were sent to eligible truck owners 

informing them of their ranking on the list and prospects 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 technology 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 accelerate the deployment of innovative 

clean air technologies that result in emissions reductions as rapidly as practicable. While 

the primary focus will be on NOx reductions, to maximize administrative efficiency and 

funding opportunities, the District will integrate when possible grant programs for 

greenhouse gases and criteria pollutant emissions reductions. 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 existing grant programs; 

• Identify specific technology focus areas; 

• Conduct comprehensive outreach; 

• Review and obtain ongoing feedback on new technology concepts; 

• Develop a competitive process for funding technology advancement projects; 

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

• Build and expand local capacity for research and development 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, business, government, district 

employees and other stakeholders. To this end, this District Division leaves “no stone 

unturned” in taking every advantage to educate the public through public appearances 

and media events throughout the Valley. This commitment also comes through with 

every employee’s interaction with the public in which every customer service interaction 

becomes an opportunity to share information about ways 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 success from implementation of the 2004 

Extreme Ozone Attainment Demonstration Plan (EOADP) for the 1-hour ozone NAAQS 
Section 6 – Innovative Strategies 51 

primarily relied on more effective regulatory controls on stationary sources at the District 

level and mobile-source regulations at the state level, such regulatory controls have 

become increasingly expensive for the regulated source operators. The District’s need 

for further reductions must be balanced with the economic 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 is 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 reducing 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 approach that involves the public, 

educational institutions, private technology innovators, and state and federal agencies. 

Only through a comprehensive and well-documented accounting of attempts and 

successes will the District be able to access all available emissions reductions 

opportunities on the road to attainment of the 8-hour ozone NAAQS. 
52 SJVAPCD 2010 Ozone Mid-Course Review 

This Page Intentionally Blank
Section 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 emissions from mobile sources; rather it 

is shared between the District, the State Air Resources Board (ARB), other State 

agencies, the EPA, and local jurisdictions. Only through the coordinated efforts of all 

these agencies will the goals of adopted air quality 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 local 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 increased 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 controlling emissions from: mobile sources and 

consumer products, except where federal law preempts ARB’s authority; developing fuel 

specifications; establishing gasoline vapor recovery standards and certifying vapor 

recovery systems; providing technical support to the districts; and overseeing local air 

district compliance with State and federal law. The State Department of Pesticide 

Regulation is responsible for control of agricultural, commercial and structural pesticides, 

while the Bureau of Automotive Repair runs the State’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 Valley 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 regulations 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 regulations 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 air quality improvements, given that 

vehicular movement, and associated emissions, to some degree, is within the control of 

the jurisdiction through development and transportation policies and codes. Federal and 

state legislation affect all levels of local government through transportation planning and 

Table 7-1 Valley Emission Reduction Estimates* from Near Term Measures Under 

Evaluation for State & Federal Measures 

2014 2020 2023 

Proposed New SIP Measures NOx VOC NOx VOC NOx VOC 

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 Clean Technology -- -- -- -- -- -- 

 Cleaner Main Ship Engines and Fuel -- -- -- -- -- -- 

 Port Truck Modernization -- -- -- -- -- -- 

 Accelerated Introduction of Cleaner Line-Haul Locomotives* 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 Standards -- 2.2 -- 4.0 -- 4.8 

 Portable Outboard Marine Tank Evaporative Standards -- 0.3 -- 0.5 -- 0.5 

 Refueling Gasoline Storage Tank Evaporative Standards -- 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 Measures 77 21 54 22 44 23 

NYQ – Not Yet Quantified 

* The State of California’s commitments for ozone attainment in the San Joaquin Valley will be for emission reductions in 2020 

and 2023. Benefits in 2014 are provided for informational purposes only and may be revised as the ARB adopts and amends 

regulations. Current the In-Use Heavy-Duty Truck rule 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 emission reductions measures 

for inclusion in the Statewide Strategy. CDPR will provide the estimated benefits of these measures in the future as part of the 

State Strategy.
Section 7 – Federal, State & Local Controls 55 

funding. The District works closely with the Metropolitan 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 attained. 

7.2.1 Regional Transportation Plans 

At the county level, the Metropolitan Planning Organizations (MPOs), representing the 

eight counties in the Valley, work in concert with their numerous municipalities, 

unincorporated areas, public interest groups, the District, and state and federal agencies 

to develop and maintain regional transportation plans (RTPs) that maximize efficient 

regional mobility and minimize unnecessary ozone precursor emissions consistent with 

emissions budgets established in the SIP. Such regional emissions budgets serve as 

regulatory limits for on-road mobile source emissions. As a condition to receive federal 

transportation funding, transportation plans, programs, and projects are required to meet 

those emission budgets through strategies that increase 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 Equity Act: A Legacy for Users 

(SAFETEA-LU). District staff review transportation plans and plan amendments to 

ensure such conformity. While Valley MPOs have limited legal authority to implement 

emission reduction measures, their status as Regional Transportation Planning Agencies 

places them in a position to help coordinate and facilitate consensus among their 

member jurisdictions, which do have authority to implement local measures. 

7.2.2 Conformity Budgets 

Section 176(c) of the CAA outlines its conformity provision. Federal actions are required 

to conform to the SIP’s purpose of eliminating or reducing the severity and number of 

exceedances of the NAAQS and achieving expeditious attainment of these standards. 

The CAA distinguishes transportation actions, or those actions undertaken by the Federal 

Highway Administration (FHWA) or the Federal Transit Administration (FTA), from all 

other federal actions. MPOs must make findings that 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 “emission 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 January 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 Plan that affect onroad mobile sources have been included in the conformity emission budgets. These 

county-level emissions are shown in Table 7-2. District controls include: 1) Existing 

Indirect Source Mitigation and School Bus Fleets rules; and 2) Rule 9410 – Employerbased Trip Reduction. ARB controls include: 1) Existing Reflash, Idling, and Carl Moyer 

Program emissions reductions; and 2) Proposed passenger vehicle and truck measures 

included in the Draft State Strategy, as shown in Table 7-1. 
56 SJVAPCD 2010 Ozone Mid-Course Review 

Table 7-2 Transportation Conformity Budgets1

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) with 

updated vehicle population and vehicle miles traveled data where available. The budget was established by taking the 

EMFAC results, subtracting by County, emission reductions from District and ARB control measures and rounding up to 

the nearest tenth if the hundredths place was “1” or higher. See Appendix C for detailed documentation supporting the 

conformity emission budget development.

The MPOs and their member jurisdictions have adopted 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 following District-adopted air quality plans: (1) 

The 2002/2005 Amended Rate of Progress Plan for San Joaquin 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 underway. For the 2007 Ozone Plan, the 

Valley MPOs drafted the local RACM approach and documentation regarding such 

implementation has been transmitted for interagency consultation. Additionally, the 

District reviews all applicable city and county plan updates, RTP amendments, FTIP 

amendments, and hot-spot analyses to ensure that they conform with District plans. 

7.2.3 Congestion Mitigation Air Quality (CMAQ) Program 

The MPOs administer the CMAQ program. The purpose of the CMAQ program is to fund 

transportation projects or programs that will contribute 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 processes 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 distributing 20 percent of the CMAQ funds to 

projects that meet a minimum cost-effectiveness beginning in FY2011. This policy will 

focus on achieving the most cost-effective emission reductions, while maintaining 

flexibility to meet local needs. The policy is scheduled 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. Due to changes in project costs and 

technology over time, the MPOs will revisit the minimum cost-effectiveness standard, as 
Section 7 – Federal, State & Local Controls 57 

well as policy feasibility. A periodic review of the policy is necessary due to potential 

changes in federal transportation legislation, apportionments, 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, state, regional, and local agencies. In light of 

the fact that mobile source emissions make up majority of the Valley’s ozone precursor 

inventory, significant dependence is place on those agencies that regulate, monitor and 

affect transportation and vehicular movement and operation. 

Significant emissions reductions will be realized through future state regulations for 

cleaner in-use heavy-duty trucks and off-road equipment. 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 jurisdictions will be critical for minimizing 

automobile emissions reductions. 

Such significant anticipated emissions reductions from mobile sources support the 

District’s analysis in Section 2 of this review, that there are still significant reductions to 

be had in the Valley, thus ensuring ozone attainment by or before the 2023 deadline. 
58 SJVAPCD 2010 Ozone Mid-Course Review 

This Page Intentionally Blank