2008 PM2.5 Plan 

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Local, State, and Federal Controls2008 PM2.5 Plan This page intentionally blank.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Chapter 7: Local, State, and Federal Controls

2008 PM2.5 Plan 7-1 

## Chapter 7: Local, State, and Federal Controls

7.1 INTRODUCTION

This chapter presents the fourth facet of the District’s contro l strategy: local, state, and federal controls. The eight Metropolitan Planning Organizations that serve the San Joaquin Valley have provided the local control information. The California Air Resources Board (ARB) provided the in formation on state control measures.

7.2 LOCAL COMPONENT: MEASURES TO REDUCE EM ISSIONS BY IMPROVING

VEHICLE USE

Motor vehicles are a large source of PM2. 5 precursor emissions in the San Joaquin Valley. The District is in a partnership wit h federal, state, and local agencies to combine efforts to reduce the impact of motor vehicles on air quality. This cooperative integration of numerous agencies addresses the difficult challenge of balancing the need to provide increased mobility for the enhancem ent of the social and ec onomic well being of our valley, with the equally important goal of attaining healthy air qua lity for all the residents. The District is involved in reducing emissi ons from motor vehicle use primarily through

its Indirect Source Review (ISR) and school bus replac ement programs; additional District control options for motor vehicle us e (including incentives) are presented in Chapter 6 and Appendix I of th is Plan. Also, ARB controls motor vehicle emissions by establishing motor vehicle emissions st andards and motor vehicle fuel formulations;

additional ARB measures devel oped for PM2.5 are described in section 7.3 of this Plan.

The San Joaquin Valley has eight f ederally designated Metropolitan Planning Organizations (MPOs), which represent the ei ght counties of the S an Joaquin Valley Air Basin. Collectively, the San Joaquin Counci l of Governments, t he Stanislaus Council of Governments, the Merced County Associat ion of Governments, the Madera County Transportation Commission, the Council of Fres no County Governments, Kings County Association of Governments, the Tulare Co unty Association of Governments and the

Kern Council of Governments work in concer t with their numerous cities, public interest groups, the District, state, and federal agencies in order to create regional transportation plans (RTPs).

7.2.1 Legislati ve Requirements

The federal Clean Air Act (CAA) regulates air pollutant emissions fr om area, stationary, and mobile sources. In addition, the CAA au thorizes the EPA to establish National Ambient Air Quality Standards (NAAQS) to protect public health and the environment. The goal of the CAA is to set maximum pollu tant standards and dire ct the states to develop SIPs for achieving and maintaining these standards.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Chapter 7: Local, State, and Federal Controls

2008 PM2.5 Plan 7-2 Because emissions from motor vehicles make a significant contribution to air pollution,

the SIP establishes an emissi ons budget for each pollutant fo r the attainment year, as well as reasonable further progre ss milestone years. This serves as a regulatory limit for

on-road mobile source emissions. As a c ondition to receive federal transportation funding, transportation plans, programs, and projects are required to meet those emission budgets through strategies that incr ease the efficiency of the transportation system and reduce motor vehicle use.

Transportation plans and programs within the S an Joaquin Valley Air Basin are also required to conform with the air quality plans in the region, as established by the Clean Air Act and reinforced by the Safe, Accountable, Flexible, Efficient Transportation Equity Act: A Legacy for Users (SAFTEA-LU). This act is the foundation for federal surface transportation laws. Transportation conformi ty is discussed in Section 7.2.2 and in Appendix C of this Plan, which includes su pporting documentation for the development of the conformity budgets.

The Valley MPOs have limited legal author ity to implement emission reduction measures. However, their status as Regi onal Planning Agencies places them in a position to help coordinate and facilitate co nsensus among their member jurisdictions, which do have authority to implement local measures.

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 Pl an for San Joaquin Valley Ozone; (2)

The Amended 2003 PM10 Plan (as amended on December 20, 2003); and (3 ) The

2004 Extreme Ozone Attainm ent Demonstration Plan. 1 Of these, EPA has only approved the measures for the 2003 PM10 Plan into the SIP. 2 The transportation

RACM for the 2003 PM10 Plan provide for the reduction of NOx and direct PM10

emissions for attainment of the PM10 standards by December 31, 2010. Implementation of these measures is underway.

It is important to note that both the local RACM and conformity budget sections were provided for interagency consultation. Cons ultation is generally conducted through the San Joaquin Valley Model Coordinating Comm ittee. The San Joaquin Valley Model Coordinating Committee (MCC) has been est ablished by the Regional Planning Agency's Executive Director's Committee to provide a coordinated approach to valley air quality, conformity and transportation model ing issues. The MCC's goal is to ensure Valley wide coordination, communication an d compliance with Federal and State Clean Air Act requirements. Each of the eight Valley MPOs and the San Joaquin Valley Unified Air Pollution Control District (SJV UAPCD) are represented. In addition, the Federal Highway Administration, Federal Tr ansit Administration, the Environmental

1 See each individual plan for a description of the m easures and the process used to develop the measures.

2 As of April 30, 2008, EPA has taken no final approval action on the Amended 2002/2005 Rate of Progress Plan for San Joaquin Valley Ozone or the 2004 Extreme Ozone Attainment Demonstration Plan

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

Chapter 7: Local, State, and Federal Controls

2008 PM2.5 Plan 7-3 Protection Agency, the California Air Resour ces Board and Caltrans are all represented

on the committee. The MCC meets approximately mo nthly; agendas, minutes, and other air quality related items are posted on the Fresno COG website at http://www.fresnocog.org . No comments were rece ived from the interagency consultation partners on either the local RACM or conformity budget sections.

Another local planning effort worth noting is the San Joaqui n Valley Regional Blueprint Planning Process. This process will result in a “visioning” plan for the Valley on behalf of the eight San Joaquin Valley regional planning agencies. The goal of the SJV Blueprint is to develop a 2050 vision for the valley that is created and shared by its residents. The Blueprint is being prepared over a 2-year period from 2006 - 2008. Public workshops will be held on a regular basis during that time to engage the public on topics of regional vision, goals, evaluati on of alternative planning scenarios, and programs and policy development. Once co mplete, the San Joaquin Valley Blueprint Planning Process will include policy and program tools to encourage local governments, business, and agriculture to im plement the vision. The District is an active participant in the Blueprint Process and is a sponsor of the project.

7.2.2 Conformity Budgets

In accordance with the 1990 Clean Air Act Am endments, conformity requirements are intended to ensure that transporta tion activities do not interfer e with air quality progress.

Section 176 of the CAA Amendm ents requires that transportat ion plans, programs, and projects conform to applicable air qual ity plans before being approved by a MPO.

Section 176(c) provides the framework for ensuring that F ederal actions conform to air quality plans under section 110. Conformity to an impl ementation plan means that proposed activities must not (1) cause or c ontribute to any new vi olation of any standard in any area, (2) increase the frequency or se verity of any existing violation of any standard in any area, or (3) delay timely attainment of any standard or any required

interim emission reductions or other milest ones in any area. For nonattainment areas

that demonstrate Reasonable Fu rther Progress (RFP) and attainment, as well as for continued maintenance of NAAQS already a ttained, EPA requires that the SIP revision specify the motor vehicle emissions on which the demonstrations are based. The plans and programs produced by the transportation pl anning process are required to conform to the budget levels in the respective plans.

EPA transportation conformity regulations est ablish criteria involv ing the comparison of projected transportation plan emissions with the motor vehicle emissions specified in the applicable air quality plans. The regul ations define the term “motor vehicle emissions budget” as meaning “the portion of t he total allowable emissions defined in a revision of the applicable implementation pl an (or in an implementation plan revision endorsed by the Governor or his or her des ignee) for a certain dat e for the purpose of meeting reasonable further progress mile stones or attainment or maintenanceSan Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Chapter 7: Local, State, and Federal Controls

2008 PM2.5 Plan 7-4 demonstrations, for any criteria pollutant or its precursors, allocated by the applicable implementation plan to highw ay and transit vehicles.” 3

PM2.5 Requirements

The Final Rule implementing the 1997 PM2.5 NAAQS (72 FR 20586) addresses the types of motor vehicle emissions that mu st be addressed when setting transportation conformity budgets. In the Final Rule , EPA notes that “RFP plans, attainment demonstrations, and maintenance plans mu st include a budget for direct PM2.5 emissions, except for certain cases as de scribed below. All PM2.5 SIP budgets would include directly emitted PM2.5 motor vehicl e emissions from tailpipe, brake wear, and

tire wear. States should also consider whether re-entrained road dust or highway and transit construction dust are significant cont ributors and should be included in the PM2.5 budget.” (72 FR 20645). The rule goes on to state that “Under ce rtain circumstances, directly emitted PM2.5 fr om on-road mobile sources may be found an insignificant contributor to the air qua lity problem and NAAQS.”

The conformity rule applies for particles wit h aerodynamic diameter less than or equal to

a nominal 2.5 micrometers (PM2.5). The precursor NOx must also be addressed unless there is a finding of insignificance.

Section 93.102(b)(2)(iv and v) of 40 CFR Part 51, subpart T identifies Volatile Organic Compounds (VOC), sulfur oxides (SOx) and/or ammonia as PM2.5 precursor pollutants

that must also have a motor vehicle emissi ons budget if deemed significant. In addition, Section 93.102(b)(3) identifies reentrai ned road dust from paved and unpaved roads as

PM2.5 emissions that must also have a motor vehicle emissions budget if deemed significant. While the applicability section of the rule does not address fugitive dust from road construction specifically, the rule does indicate that the consultation process should be used during the development of PM2.5 SIPs when construction emissions are a significant contributor, so that these emissions are incl uded in the SIP’s motor vehicle emissions budget for conformity purposes.

The rule also indicates that, as a practical matter, conformity for ammonia would not be required in California until there is an acc eptable method for estima ting such emissions,

because a method would be needed to estimate current or future ammonia emissions for either a significance finding or SIP motor v ehicle emissions budget. It is important to

note that EMFAC 2007 does not estimate onroad mobile ammonia emissions. In addition, this plan indicates ammonia is abundant throughout the Valley and does not act as a limiting precursor, which means r educing ammonia is ineffective in reducing PM2.5 in the Valley. Consequently, ammonia emissions are NOT included in the motor vehicle emissions budgets fo r conformity purposes.

3 Federal transportation conformity regulat ions are found in 40 CFR Part 51, subpart T – Conformity to State or Federal Implementation Plans of Transportation Pl ans, Programs, and Projects Developed, Funded or Approved Under Title 23 U.S.C. of the Federal Transit Laws. Part 93, subpart A of this chapter was revised by the EPA in the August 15, 1997 Federal Register.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Chapter 7: Local, State, and Federal Controls

2008 PM2.5 Plan 7-5 The conformity rule indicates that the follo wing criteria will be co nsidered in making significance or insignificance findings for PM 2.5 precursors: the contribution of on-road emissions of the precursor to the total 2002 baseline SIP inv entory; the current state of air quality for the area; the results of spec iation monitoring for the area; the likelihood

that future motor vehicle control measures will be implemented for a given precursor; and projections of future on-road emissions of the precursor.

In addition, significance findings for re-entra ined road dust emissions will be based on a review of the following factors: the contributi on of road dust to current and future PM2.5 nonattainment; an area’s current design value for the PM2.5 standard; whether controlof road dust appears necessary to reach attainment; and whether increases in reentrained dust emissions may interfere with attainment. Such a review would include consideration of local air quality data and/or air quality or emissions modeling results.

Assessment of Significance

It is important to note that 4 of the 8 count ies are already in attainment with the PM2.5 standards and 2 others are project ed to be in attainment by 2014 with existing controls. The air quality modeling for t he attainment demonstrati on shows that NOx is the dominant pollutant for reducing PM2.5 concentration in the Va lley, which indicates that

NOx controls are the most ef fective way to reduce PM2.5 levels in the Valley. The proposed control strategy for NOx results in attainment of the annual standard in 2014

for the other 2 counties.

VOC: While the onroad mobile estimates fo r VOC are approximatel y 18 percent of the total, they continue to decrease over time. Similar to PM-10, the air quality modeling indicates that VOC is not a significant pr ecursor to secondary PM2.5 formation in the San Joaquin Valley Air Basin. Accordingl y, motor vehicle emissions budgets for VOC are NOT being established.

SOx: Onroad mobile exhaust estimates are less than 1 ton per day valley wide in the budget years, which equates to approximately 3 percent of the total SOx emissions inventory. In addition, the onroad emissions total remains essentially constant from 2009 to 2014, despite the increasing VMT. SO x controls are focused on industrial sources as they contribute almost 90 percent of the total inventory. As a result, onroad

SOx emissions are NOT included in the motor vehicle emissi ons budgets for conformity

purposes.

Paved Road Dust: For this 2008 PM2.5 Plan, the paved road dust direct PM2.5 emission inventory is a small percentage of total direct PM2.5 emissions for all source categories; in 2005, paved road dust represents only 6% of the total, and in 2014 this increases to only 7%. As noted in Chapter 9, all geologic and construction source categories combined represent only about 7. 5% of the annual PM 2.5 concentrations measured in the Valley. Since paved r oad dust is about 20% of the geologic and

construction emissions shown in the area-wi de categories in the inventory (Appendix B), the contribution of paved road dust to ambi ent PM2.5 concentrations is only about 1%San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Chapter 7: Local, State, and Federal Controls

2008 PM2.5 Plan 7-6 (assuming that relative ambient contributions reflect relative emissions contributions). In addition, there are no fugitive dust contro ls included in the attainment demonstration for this plan; however, paved road dust is controlled via the PM-10 Plan and is evaluated continually as part of the PM-10 conformity determinations. As a result, paved road dust emissions are NOT included in the motor v ehicle emissions budgets for conformity purposes.

Unpaved Road Dust: Total unpaved road dust is estimated at approx imately 4 tons per day valley wide, which equates to approximately 5 percent of the total PM2.5 emissions inventory. Local roads are a sub-part of this category a nd are less than 0.6 tons per day, which is less than 1 percent valley wide and therefore considered insignificant. In addition, there are no fugitive dust contro ls included in the plan; however, unpaved road dust is controlled via the PM-10 Plan, includ ing the prohibition of any new local unpaved roads, and is evaluated as continually as par t of the PM-10 conformity determinations. As a result, unpaved road dust emissions are NOT included in the motor vehicle emissions budgets for conformity purposes.

Construction Dust: Total construction and demolition direct PM 2.5 emissions are approximately 1 ton per day valley wide, whic h equates to approximately 1.5 percent of

the total PM2.5 emissions inve ntory. Road construction is a sub-part of this category and is less than 0.3 tons per day, which is less than 0.5 percent valley wide, which is considered insignificant. In addition, there are no fugitive dust controls included in the plan; however, road construction dust is cont rolled extensively via the PM-10 Plan and is evaluated as continually as part of the PM -10 conformity determinations. As a result,

road construction emissions are NOT include d in the motor vehicle emissions budgets for conformity purposes.

Conformity Budgets

This plan includes reasonable further progre ss demonstrations for 2009 and 2012 and

attainment of the PM2.5 standar d is projected by 2014. Av erage annual day emissions are used in the plan to address both the 24-hour and annual standards. Consequently, conformity budgets have been estimated for the analysis years 2009, 2012, and 2014.

Section 93.124(e) of the federal conformity rule indicates that nonattainment areas with more than one MPO may establish motor vehi cle emission budgets for each MPO in the implementation plan. As a result, County-le vel emission budgets are provided in this plan.

The budgets are derived starti ng with projections from ARB’s EMFAC 2007 on-road

mobile source emission fact or model. The emission budget s are based on the latest MPO VMT data and speed distributions (s ee 2007 Conformity Analyses) where

available. The EMFAC 2007 model runs in clude the updated VMT through adjustments to vehicle population per the EPA approv ed ARB Recommended Methods for use of EMFAC2002 To Develop Motor Vehicle Em issions Budgets and Assess Conformity (note that ARB has indicat ed the methods will remain unchanged with the transition toSan Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Chapter 7: Local, State, and Federal Controls

2008 PM2.5 Plan 7-7 EMFAC 2007). Updated speed distributions are input directly. If updated MPO VMT data and speed distributions were not ava ilable, the EMFAC 2007 default data was

used.

District and ARB control measures which r educe on-road mobile source emissions but

are not included in EMFAC 2007 are included in the Plan and have been included in the conformity emission budgets. District controls include:

• existing Indirect Source Mitigation and School Bus Fleets rules

• Note: reductions from proposed Employ ee Trip Reduction are not included since they are not quantified in this SIP.

ARB controls include:

• existing Heavy-duty truck “reflash” r eductions, public fleet emission controls, Heavy-duty Truck Idling limits, co- benefits of AB 1493 greenhouse gas tailpipe emission controls, and Carl Moyer Program reductions

• Passenger vehicle and truck measures included in the Adopted 2007 State Strategy (see Table 7-1).

While valley-wide emission reductions are presented throughout the Plan, by County

emission reduction estimates have been estima ted for inclusion in the conformity emission budgets. In general , by County emission estimates were calculated by distributing the valley-wide em ission reductions by population or ratio of emissions subcategory to total motor vehi cle estimate (e.g., heavy-duty truck emissions/total motor vehicle emissions). Table 7-1 and 7-2 refl ects these emission reductions. Detailed documentation supporting the conformity em ission budget development is contained in Appendix C. The followin g provides a sample budget calculation.

Table 7-1 Example County Em ission Budget Calculation (tons per average annual day)

PM2.5 NOx

Emissions Baseline

Baseline EMFAC 2007 1.65 40.60

State and Local Measures not included in

EMFAC 07 0.02 4.03

ARB 2007 State Strategy 0.61 11.31 Conformity Emissions Budgets* 1.1 25.3 * Rounded up to the nearest tenth.

This plan establishes subarea county em ission budgets for PM2.5 and NOx for the horizon years 2009, 2012, and 2014. Appendix C provides more detailed calculations.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Chapter 7: Local, State, and Federal Controls

2008 PM2.5 Plan 7-8 Table 7-2 Transportati on Conformity Budgets (tons per average annual day)

2009 2012 2014 County PM2.5 NOx PM2.5 NOx PM2.5 NOx

Fresno 2.2 56.5 1.9 44.2 1.1 26.0 Kern (SJV) 3.4 87.7 3.0 74.2 1.4 41.6 Kings 0.7 17.9 0.6 14.6 0.3 8.1

Madera 0.6 14.1 0.5 11.4 0.3 6.7

Merced 1.5 33.6 1.2 26.7 0.6 14.8 San Joaquin 1.6 39.1 1.4 32.8 0.9 20.3

Stanislaus 1.0 25.8 0.9 20.8 0.5 12.4

Tulare 0.9 23.3 0.8 19.5 0.5 12.2

7.2.3 Local Reasonably Available C ontrol Measure (RACM) Strategy

The Clean Air Act (Section 172 (c)(1)) require s State Implementation Plans (SIPs) to contain Reasonably Available Control Measures (RACM) to provide for attainment of the air quality standard as expeditiously as practicable. The PM2.5 Implementation Rule (72FR20586) also contains regulator y language requiring RACM analyses for all source categories (stationary, area, and mob ile) in PM2.5 SIPs (40CFR51.1010). The San Joaquin Valley Air Pollution Control Dis trict (SJVAPCD) requested that the Valley Metropolitan Planning Organizations (MPOs) devel op Local RACM for the PM2.5 SIP.

In December 2006, the SJV MPOs pr epared documentation for the Draft Implementation of Local Reasonably Availa ble Control Measure (RACM) strategy for the 8-Hour Ozone SIP. The strategy consist ed of two parts: (1) evaluation of potential RACM for advancing the attainment dat e and (2) the adoption of a Congestion Mitigation and Air Quality (CMAQ) policy to fund cost-effective emission reduction projects.

For the PM2.5 efforts, the evaluation of potential RACM for advancing the attainment date was re-visited and updated accordingly. In addition, the CMAQ policy has been adopted by all eight SJV MPOs that include s developing a standardized process across the Valley for distributing 20 percent of t he CMAQ funds to projects that meet a minimum cost-effectiveness beginning in FY2011. This policy focuses on achieving the most cost-effective emission reductions, while main taining flexibility to meet local needs.

Evaluation of Potential RACM for Advancing Attainment Date

The MPOs have applied EPA’s final rule to implement the PM2.5 standard for identifying the RACM commitments. The EPA rule reinforces earlier RACM guidance providing for a limited RACM analysis of ava ilable measures, an estimate of emission reductions, and examination of the time needed to implement the measures. If it is

demonstrated that the combined local RACM can not advance t he attainment date by atSan Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Chapter 7: Local, State, and Federal Controls

2008 PM2.5 Plan 7-9 least one year, then those additional measur es are not deemed “reas onably available” under EPA policy and do not need to be included in the State Implementation Plan (SIP). The evaluation of pot ential RACM for advancing the attainment date is presented in three steps as documented below.

Step 1: The list of local control measur es developed for the 8-Hour Ozone Plan was reviewed. Documentation for development of the list of control m easures for possible

consideration is contained in Appendix C of the 2007 Ozone Plan. Steps 1 – 6 resulted

in an extensive list of control measures for consideration and demonstrates due diligence in identifying potent ial local RACM; in total, over 65 documents were referenced in developing the list of cont rol measures for consideration.

Additionally, for the PM2.5 plan developm ent, the PM2.5 Implementation Rule was

reviewed to assure that there were no su ch changes made to the RACM policy that

would result in additional measures for cons ideration. It shoul d be noted that EPA has not established mandatory measures for a ll areas to consider as RACM and EPA continues to suggest that RACM be an area- by-area decision. All relevant PM2.5

measures contained in the rule were alread y included in the list of potential RACMs reviewed and analyzed in the 8-hour Ozone SIP. Also, the EPA draft list of measures

included in the ozone RA CM analysis dated Decem ber 2006 was finalized (see http://www.epa.gov/air/particles/measures.html ) and reviewed again for any additional

PM2.5 control measures that would need to be considered as potential RACMs in this

PM2.5 SIP.

Furthermore, the process for the PM2.5 plan includes a review of new plans and measures developed for consideration since April 2007, including the South Coast 2007 Air Quality Management Plan (AQMP) and the New Jersey 2007 SIP. It is important to

note that while there are at least 66 designated PM2.5 areas in the nation, we were unable to find additional PM2.5 SIP strategi es to review. Some areas are not proceeding with SIP development since the EPA PM2.5 implementation rule has been comprehensively challenged by the environm ental community in the DC Circuit, and some are awaiting the need to address the revised PM2.5 NAAQS.

The adopted South Coast 2007 (AQMP) was re viewed to see if any additional RACMs had been identified. This AQMP combines regul ations and control measures to attain the PM2.5 standard by 2015 and the 8-hour ozone standard by 2024. The AQMP was bifurcated to address both pollutants, as most of the contro l strategies are complementary. The Draft AQMP’s RACM approach, which is discussed in Appendix IV-C of that plan, was previously reviewed as part of the ozone RACM efforts. It clearly

states that all the RACMs and Transportation Control M easures (TCM) in the final
AQMP were taken from the 2004 RTP and 2006 RTIP. Thus, these were previously reviewed during the original analysis of RA CMs in the SJV 8-hour final Ozone SIP.
While the South Coast AQMP identified numer ous TCMs, they were all specific to individual transportation projects in thei r 2006 RTIP and not general in scope. In summary, no new measures for which local agencies have implementation authorities
were found in the final South Coast 2007 AQMP.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Chapter 7: Local, State, and Federal Controls

2008 PM2.5 Plan 7-10 In June, 2007, the New Jersey Department of Environmental Protection submitted an 8-

hour Ozone SIP to the EPA. It contains an extensive analysis of RACM and Reasonably Available Control Technology (RACT). Beginning with a list of 457 potential control measures (a ll categories), New Jersey identified 26 TCMs and onroad

mobile measures for use in EPA’s RACM analysis review gui delines, i.e., must advance the attainment date by one year. The “political feasibility” criteria narrowed the list to 11 measures and those advanced to final RACM analysis. These measures have been analyzed and it has been determined that all “non- NJ specific” measures are contained in some form in the 8-hour ozone RACM analysis (see Table C.6).

In summary, no new additional measures were identified from those considered for the 8-Hour Ozone Plan RACM analysis in this PM2.5 RACM evaluation.

Step 2: As documented in the 2007 Ozone Pl an, emission reduction estimates were developed for the Section 108(f) categories to assess the local RACM list of applicable

measures. The maximum feasible emissi on reduction for NOx estimated from implementing all of those TCMs was approxim ately 7 tons per day (tpd) in 2020 and 5 tpd in 2023. Those estimates were based on the maximum travel reductions that could be expected from applicable measures and t he average gram/mile emission rate of light-duty vehicles (i.e., passenger cars and light-duty trucks) operated during the

summer.

A review of the SIP shows that 75% of annual PM2.5 concentrations can be attributed to the period between November and January and that ammonium nitrate is the main component of PM2.5 during the winter. The California Regiona l Particulate Air Quality Study (CRPAQS) found that redu ctions in NOx emissions are more effective in reducing secondary ammonium nitrate aerosol concentrat ions. Similarly, the control measures

selected in the SIP have focused on NOx redu ctions to demonstrate attainment. For these reasons, NOx is the pollutant to be considered when assessing whether TCM

reductions can advance attainment.

Since NOx formation is directly influenced by combustion temperature, motor vehicle NOx emission rates are higher during the su mmer than during either the winter or on annual average basis when average temperatures are lower. This means that NOx reductions estimated for 108(f) measur es during summer months provide a conservative (i.e., higher or greater) esti mate of the reductions that can be expected

from these measures on either an annual average or winter basis.

Due to the benefits of fleet tu rnover (i.e., replacement of older scrapped vehicles with newer vehicles) and increasi ngly stringent motor vehicle emission standards, the fleet average emission rates in 2020 and 2023 are lower than those in 2013/2014. This

means the NOx reductions estimated in 2020 and 2023 underestimate the reductions that could be produced in earlier years. To quantify the impact of those reductions in 2013, fleet average NOx emission rates were computed for light-duty vehicles in that year. This value was used to adjust the 7 tpd reduction estimated in 2020 by the ratio of 2013/2020 average NOx rates. The ratio was computed to be 2.07, which means thatSan Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Chapter 7: Local, State, and Federal Controls

2008 PM2.5 Plan 7-11 TCMs analyzed for the ozone plan are estimated to produce a reduction of roughly 14 tpd in 2013 (assuming the same level of tr avel reductions apply in 2013 as did in 2020 and 2023).

Step 3: The emission reduction estimate s were compared against the attainment

demonstration information contained in t he February 2008 version of the Draft 2008 PM2.5 Plan to determine if they collectiv ely advance attainment by a full year. According to Table 9-1, an additional 100. 5 tons per average annual day of NOx emission reductions is necessary in 2013 to advance attainment of the PM2.5 plan by one year. As shown in Step 2, the maximu m NOx reductions that can be expected from the applicable TCMs in 2013 is on the order of 14 tpd. Since this estimate is conservative (i.e., it is based on summe r emission rates and annual average values will be lower) and falls far short of the 100.5 t pd reduction needed to advance attainment by a year, the emission reducti on analysis concludes that the TCM categories will not

advance attainment for the PM2.5 Plan.

In conclusion, the local PM2.5 RACM analys is finds that the potential measures

identified will not advance attain ment by a full year and ther efore, no further efforts to adopt additional local commitments for the SIP are necessary.

7.3 SUMMARY OF THE STATE STRAT EGY ADOPTED BY THE AIR RESOURCES

BOARD

On September 27, 2007, the Air Resources Board (ARB or Board) adopted the state emission reduction strategy to achieve ne w emission reductions needed to bring areas

of the State into attainment of both t he federal PM2.5 and ozone air quality standards.

The commitment for 2014 in the state strate gy includes reductions needed to attain the PM2.5 standards and provide progress to wards meeting the ozone standard.

Through the public consultation process de scribed below, ARB staff obtained input on California’s State Implementation Plan (SIP) e fforts. In October 2006, ARB staff held a SIP Symposium, followed by a workshop in November to discuss development of potential control concepts fo r meeting the federal 8-hour ozone and PM2.5 standards. In January 2007, ARB staff circ ulated for public review, the Draft Air Resources Board’s Proposed State Strategy for Californi a’s 2007 State Implementation Plan (Proposed State Strategy) and, in April 2007, conduc ted a series of public workshops. On April 26, 2007, ARB staff released a revised draft of the Proposed State Strategy that incorporated changes based on further staff analysis and public comments. ARB staff also participated in SIP workshops conduct ed by the staff of the San Joaquin Valley

APCD to discuss how the statewide control measures fit into the local 8-hour ozone strategy. At the June 2007 Board hearing, t he Board directed staff to work with the San Joaquin Valley APCD to identify additi onal measures to achieve emission reductions sooner in the Valley. As a re sult, in September 2007, the Board adopted the Revised Proposed State Strategy. The Re vised State Strategy includes the April 26, 2007 total emission reduction co mmitments to be accomplished by 2014 forSan Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Chapter 7: Local, State, and Federal Controls

2008 PM2.5 Plan 7-12 attainment of the PM2.5 standard in the Valley, and strengthened commitments to be accomplished by 2017 for the 8-hour ozone standard.

The quantified emission reduction estimates for 2014 from the mix of concepts in the state strategy in the San Joaquin Valley ar e shown in Table 7-3. The San Joaquin Valley is relying on NO x, direct PM2.5, and SO 2 emission reductions to demonstrate

attainment of the PM2.5 N AAQS; the state measures em phasize NOx and direct PM2.5

reductions. This section also includes shor t descriptions of the measures currently under evaluation by ARB staff.

Table 7-3 Expected Emission Reducti ons from 2007 SIP State Strategy (tons per day) San Joaquin Valley -- 2014

Proposed New State SIP Measures NOx ROG Direct

PM2.5 SOx

Passenger Vehicles 3.8 6.5 0.1 -- Smog Check Improvements (BAR) 3.3 2.9 0.05 -- Expanded Vehicle Retirement 0.5 0.7 0.01 -- Modifications to Reformulated Gasoline Program -- 2.9 -- --

Heavy-Duty Trucks 61.4 6.4 3.6 --

Cleaner In-Use Heavy-Duty Trucks 61.4 6.4 3.6 --

Goods Movement Sources 7.2 0.5 0.2 -- Ship Auxiliary Engine Cold Ironing & Clean Technology -- -- -- -- Cleaner Main Ship Engines and Fuel -- -- -- --

Port Truck Modernization -- -- -- --

Accelerated Introduction of Cleaner Line-Haul Locomotives 7.2 0.5 0.2 -- Clean Up Existing Harbor Craft -- NYQ -- --

Off-Road Equipment 3.7 0.9 0.8 -- Cleaner In-Use Off-Road Equipment (over 25hp) 3.7 0.9 0.8 -- Cleaner In-Use Agricultural Equipment NYQ NYQ NYQ --

Other Off-Road Sources 0.1 3.5 -- -- New Emission Standards for Re creational Boats 0.1 1.3 -- -- Expanded Off-Road Rec. Vehicle Emission Standards -- 2.2 -- -- Additional Evaporative Emi ssion Standards -- NYQ -- NYQ Vapor Recovery for Above Ground Storage Tanks -- NYQ -- NYQ

Areawide Sources -- 5.7 -- -- Consumer Products Program -- 3.2 -- -- Pesticides: DPR Regulation -- 2.5 -- --

Reductions from Proposed New State Measures 76 23 5 0

Reductions from Adopted State Measures 211 49 7 0

Total Emission Reductions from State Strategy 287 72 12 0

NYQ = Not Yet Quantified. BAR = Bureau of Automoti ve Repair. DPR = Dept. of Pesticide Regulation

Locomotives measure relies on U.S. EPA rulemaking and industry agr eement to accelera te fleet turnover. Note: Emission reductions reflect the combined impact of regulations and supportive incentive programs. Emission reduction estimates for each proposed meas ure are shown for informational purposes only. Actual emission reductions from any particular me asure may be greater than or less than the amounts

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

Chapter 7: Local, State, and Federal Controls

2008 PM2.5 Plan 7-13 Overview of the 2007 Statewide Strategy

Responsibility for implementing emission re duction measures is shared between the agencies with primary responsibility for controlling air pollution in California: the State Air Resources Board (ARB), 35 local air pollution control and air quality management districts (air districts), and the U.S. Environmental Protection Agency (U.S. EPA).

ARB is responsible for controlling emissions from mobile sources (except where federal law preempts ARB’s authority) and consumer products, developing fuel specifications, establishing gasoline vapor recovery standar ds and certifying vapor recovery systems, providing technical support to the districts, and overseeing lo cal district compliance with

State and federal law. The St ate Department of Pesticide R egulation is responsible for control of agricultural, commercial and stru ctural pesticides, while the Bureau of Automotive Repair runs the State’s Sm og Check programs to identify and repair polluting cars.

In the San Joaquin Valley, em ission reductions from the existing federal, State, and local source control program are not enough to attain the federal standards. Consequently, further emissi on reductions from new measures must be achieved in

order to meet the emission reduction target. In Septem ber 2007, the Board approved the State Strategy for California’s 2007 Stat e Implementation Plan. The new measures that provide attainment of the PM2.5 standards in t he San Joaquin Valley under consideration by ARB staff are summarized below. For a comprehensive list of measure descriptions in the State Strategy visit:

http://www.arb.ca.gov/plann ing/sip/2007sip/2007sip.htm

Passenger Vehicles

Improvements and Enhancements to California’s Smog Check Program

• More Stringent Cutpoints. More stringent pass/fail cutpoints would require more cars to be repaired, and help ensur e more complete and durable repairs.

• Annual Inspections for Older Vehicles . Inspect older vehicles annually rather than every two years. Older vehicles tend to have greater deterioration of emission controls, and consequently, higher emissions.

• Annual Inspections for High Annual Mileage Vehicles. Inspect annually, rather than every two years, vehicles t hat accrue very high mileage on a yearly basis. High mileage vehicles tend to hav e greater deteriora tion of emission controls, and consequently, higher emissions.

• Add Visible Smoke Test . As part of the Smog Check test, include a check for visible smoke to identify vehicles with exce ss particulate matter (PM) emissions.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Chapter 7: Local, State, and Federal Controls

2008 PM2.5 Plan 7-14 • Inspection of Light and Medium Duty Diesels. Include light and medium duty diesel vehicles in the Smog Check program to provide for improved maintenance and reduced emissions for this part of t he fleet, and require the repair of poorly maintained or old emission systems.

• Inspection of Motorcycles. Include motorcycle inspections as part of Smog Check. Studies indicate that motorcycl es are subject to high rates of exhaust system tampering.

Expanded Passenger Vehicle Retirement. Increase the number of vehicles that are voluntarily retired by impl ementing a scrappage program for v ehicles that are off cycle from their Smog Check inspections.

Heavy-Duty Trucks

Cleaner In-Use Heavy-Duty Trucks. This proposed measure is a comprehensive in-use diesel truck emissions reduction progr am that includes a fleet modernization rule and an enhanced screening and repair program. Fleet modernization would focus on overcoming the typically slow rate of heavy-duty truck turnover by requiring truck owners to meet specified emission levels through replacing or cleaning up the oldest trucks in their fleets, and would also incl ude a program for out-o f-state trucks operating in California. ARB’s roadside heavy-dut y vehicle inspection program would be expanded to more effectively identify and screen trucks that need emission control system repairs. In addition, under the Go ods Movement Program, incentive funding

would be available to accelerate or attain surplus emission reductions. ARB rulemaking for this measure is underway.

Goods Movement Sources

Accelerated Introduction of Clean er Line Haul Locomotives. Replace existing locomotive engines with cleaner Tier 3 engines beginning in 2012 and conduct

concurrent rebuilds of older engines to Tier 2.5 standards. This measure can only occur once U.S. EPA adopts Tier 3 engine standards for locomotives.

Off-Road Equipment

Cleaner In-Use Off-Road Equipment. Establish fleet average emission limits for off-road equipment (over 25 horsepower) t hat requires older, dirtier engines to be replaced with engines reflecting current technol ogies or retrofitted with emission control

devices. The measure also includes setti ng idling limits. In July 2007, the Board approved this rule for adoption. In addition, the Board approved an opt-in provision for a regional incentive program to achiev e additional NOx reductions, the Surplus Off-Road Opt-in for NOx (SOON) program. ARB will continue working with the San Joaquin Valley APCD to identi fy funding for the SOON program.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Chapter 7: Local, State, and Federal Controls

2008 PM2.5 Plan 7-15 Cleaner In-Use Agricultural Equipment. Accelerate the modernization of the agricultural equipment fleet used in Californi a, removing older, dirtier equipment from service to be replaced with engines reflecti ng cleaner technologies. Availability of incentives along with equipment avail ability will determine how soon emission

reductions will be realized.

Other Off-Road Sources

New Emission Standards for Recreational Boats. Adopt catalyst-based standards (5 g/kW-hr) for new outboard engi nes and evaporative emission standards.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Chapter 7: Local, State, and Federal Controls

2008 PM2.5 Plan 7-16 This page intentionally blank.