2008 PM2.5 Plan 

Chapter 7 

 

Local, State, and Federal Controls 
2008 PM2.5 Plan 

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Chapter 7: Local, State, and Federal Controls

7.1 INTRODUCTION 

This chapter presents the fourth facet of the District’s control 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 information on state control measures. 

7.2 LOCAL COMPONENT: MEASURES TO REDUCE EMISSIONS 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 with 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 enhancement of the social and economic well being of our 

valley, with the equally important goal of attaining healthy air quality for all the residents. 

The District is involved in reducing emissions from motor vehicle use primarily through 

its Indirect Source Review (ISR) and school bus replacement programs; additional 

District control options for motor vehicle use (including incentives) are presented in 

Chapter 6 and Appendix I of this Plan. Also, ARB controls motor vehicle emissions by 

establishing motor vehicle emissions standards and motor vehicle fuel formulations; 

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

The San Joaquin Valley has eight federally designated Metropolitan Planning 

Organizations (MPOs), which represent the eight counties of the San Joaquin Valley Air 

Basin. Collectively, the San Joaquin Council of Governments, the Stanislaus Council of 

Governments, the Merced County Association of Governments, the Madera County 

Transportation Commission, the Council of Fresno County Governments, Kings County 

Association of Governments, the Tulare County Association of Governments and the 

Kern Council of Governments work in concert with their numerous cities, public interest 

groups, the District, state, and federal agencies in order to create regional transportation 

plans (RTPs). 

7.2.1 Legislative Requirements 

The federal Clean Air Act (CAA) regulates air pollutant emissions from area, stationary, 

and mobile sources. In addition, the CAA authorizes 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 pollutant standards and direct the states to 

develop SIPs for achieving and maintaining these standards. 
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Because emissions from motor vehicles make a significant contribution to air pollution, 

the SIP establishes an emissions budget for each pollutant for the attainment year, as 

well as reasonable further progress milestone years. This serves as a regulatory limit 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 San 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 conformity is discussed in Section 7.2.2 and in 

Appendix C of this Plan, which includes supporting documentation for the development 

of the conformity budgets. 

 

The Valley MPOs have limited legal authority to implement emission reduction 

measures. However, their status as Regional 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. 

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 Extreme Ozone Attainment 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. Consultation is generally conducted through the 

San Joaquin Valley Model Coordinating Committee. The San Joaquin Valley Model 

Coordinating Committee (MCC) has been established by the Regional Planning 

Agency's Executive Director's Committee to provide a coordinated approach to valley 

air quality, conformity and transportation modeling issues. The MCC's goal is to ensure 

Valley wide coordination, communication and 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 (SJVUAPCD) are represented. In addition, the 

Federal Highway Administration, Federal Transit Administration, the Environmental 

 

1

 See each individual plan for a description of the measures 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. 
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Protection Agency, the California Air Resources Board and Caltrans are all represented 

on the committee. The MCC meets approximately monthly; agendas, minutes, and 

other air quality related items are posted on the Fresno COG website at 

http://www.fresnocog.org. No comments were received from the interagency 

consultation partners on either the local RACM or conformity budget sections. 

Another local planning effort worth noting is the San Joaquin 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, evaluation of alternative planning scenarios, and 

programs and policy development. Once complete, the San Joaquin Valley Blueprint 

Planning Process will include policy and program tools to encourage local governments, 

business, and agriculture to implement 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 Amendments, conformity requirements are 

intended to ensure that transportation activities do not interfere with air quality progress. 

Section 176 of the CAA Amendments requires that transportation plans, programs, and 

projects conform to applicable air quality plans before being approved by a MPO. 

Section 176(c) provides the framework for ensuring that Federal actions conform to air 

quality plans under section 110. Conformity to an implementation plan means that 

proposed activities must not (1) cause or contribute to any new violation of any standard 

in any area, (2) increase the frequency or severity 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 milestones in any area. For nonattainment areas 

that demonstrate Reasonable Further Progress (RFP) and attainment, as well as for 

continued maintenance of NAAQS already attained, 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 planning process are required to conform 

to the budget levels in the respective plans. 

EPA transportation conformity regulations establish criteria involving the comparison of 

projected transportation plan emissions with the motor vehicle emissions specified in 

the applicable air quality plans. The regulations define the term “motor vehicle 

emissions budget” as meaning “the portion of the total allowable emissions defined in a 

revision of the applicable implementation plan (or in an implementation plan revision 

endorsed by the Governor or his or her designee) for a certain date for the purpose of 

meeting reasonable further progress milestones or attainment or maintenance 
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demonstrations, for any criteria pollutant or its precursors, allocated by the applicable 

implementation plan to highway 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 must be addressed when setting transportation 

conformity budgets. In the Final Rule, EPA notes that “RFP plans, attainment 

demonstrations, and maintenance plans must include a budget for direct PM2.5 

emissions, except for certain cases as described below. All PM2.5 SIP budgets would 

include directly emitted PM2.5 motor vehicle 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 contributors and should be included in the PM2.5 

budget.” (72 FR 20645). The rule goes on to state that “Under certain circumstances, 

directly emitted PM2.5 from on-road mobile sources may be found an insignificant 

contributor to the air quality problem and NAAQS.” 

The conformity rule applies for particles with 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 emissions budget if deemed significant. In addition, 

Section 93.102(b)(3) identifies reentrained 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 included 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 acceptable method for estimating such emissions, 

because a method would be needed to estimate current or future ammonia emissions 

for either a significance finding or SIP motor vehicle 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 reducing ammonia is ineffective in reducing 

PM2.5 in the Valley. Consequently, ammonia emissions are NOT included in the motor 

vehicle emissions budgets for conformity purposes. 

 

3

 Federal transportation conformity regulations are found in 40 CFR Part 51, subpart T – Conformity to State or Federal 

Implementation Plans of Transportation Plans, 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. 
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The conformity rule indicates that the following criteria will be considered in making 

significance or insignificance findings for PM2.5 precursors: the contribution of on-road 

emissions of the precursor to the total 2002 baseline SIP inventory; the current state of 

air quality for the area; the results of speciation 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-entrained road dust emissions will be based on a 

review of the following factors: the contribution of road dust to current and future PM2.5

nonattainment; an area’s current design value for the PM2.5 standard; whether control 

of 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 counties are already in attainment with the PM2.5 

standards and 2 others are projected to be in attainment by 2014 with existing controls. 

The air quality modeling for the attainment demonstration shows that NOx is the 

dominant pollutant for reducing PM2.5 concentration in the Valley, which indicates that 

NOx controls are the most effective 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 for VOC are approximately 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 precursor to secondary PM2.5 formation in the 

San Joaquin Valley Air Basin. Accordingly, 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. SOx 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 emissions 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 PM2.5 concentrations 

measured in the Valley. Since paved road dust is about 20% of the geologic and 

construction emissions shown in the area-wide categories in the inventory (Appendix B), 

the contribution of paved road dust to ambient PM2.5 concentrations is only about 1% 
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(assuming that relative ambient contributions reflect relative emissions contributions). 

In addition, there are no fugitive dust controls 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 vehicle emissions budgets for 

conformity purposes. 

Unpaved Road Dust: Total unpaved road dust is estimated at approximately 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 and 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 controls included in the plan; however, unpaved road 

dust is controlled via the PM-10 Plan, including the prohibition of any new local unpaved 

roads, and is evaluated as continually as part 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 PM2.5 emissions are 

approximately 1 ton per day valley wide, which equates to approximately 1.5 percent of 

the total PM2.5 emissions inventory. 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 controlled 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 included in the motor vehicle emissions budgets 

for conformity purposes. 

Conformity Budgets

This plan includes reasonable further progress demonstrations for 2009 and 2012 and 

attainment of the PM2.5 standard is projected by 2014. Average 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 vehicle emission budgets for each MPO in the 

implementation plan. As a result, County-level emission budgets are provided in this 

plan. 

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

mobile source emission factor model. The emission budgets are based on the latest 

MPO VMT data and speed distributions (see 2007 Conformity Analyses) where 

available. The EMFAC 2007 model runs include the updated VMT through adjustments 

to vehicle population per the EPA approved ARB Recommended Methods for use of 

EMFAC2002 To Develop Motor Vehicle Emissions Budgets and Assess Conformity 

(note that ARB has indicated the methods will remain unchanged with the transition to 
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EMFAC 2007). Updated speed distributions are input directly. If updated MPO VMT 

data and speed distributions were not available, the EMFAC 2007 default data was 

used. 

District and ARB control measures which reduce 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 Employee Trip Reduction are not included since 

they are not quantified in this SIP. 

ARB controls include: 

• existing Heavy-duty truck “reflash” reductions, 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 estimated for inclusion in the conformity 

emission budgets. In general, by County emission estimates were calculated by 

distributing the valley-wide emission reductions by population or ratio of emissions subcategory to total motor vehicle estimate (e.g., heavy-duty truck emissions/total motor 

vehicle emissions). Table 7-1 and 7-2 reflects these emission reductions. Detailed 

documentation supporting the conformity emission budget development is contained in 

Appendix C. The following provides a sample budget calculation. 

Table 7-1 Example County Emission 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 emission budgets for PM2.5 and NOx for the 

horizon years 2009, 2012, and 2014. Appendix C provides more detailed calculations. 
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Table 7-2 Transportation 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 Control Measure (RACM) Strategy 

The Clean Air Act (Section 172 (c)(1)) requires 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 regulatory language requiring RACM analyses for all 

source categories (stationary, area, and mobile) in PM2.5 SIPs (40CFR51.1010). The 

San Joaquin Valley Air Pollution Control District (SJVAPCD) requested that the Valley 

Metropolitan Planning Organizations (MPOs) develop Local RACM for the PM2.5 SIP. 

In December 2006, the SJV MPOs prepared documentation for the Draft 

Implementation of Local Reasonably Available Control Measure (RACM) strategy for 

the 8-Hour Ozone SIP. The strategy consisted of two parts: (1) evaluation of potential 

RACM for advancing the attainment date 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 includes 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 focuses on achieving the 

most cost-effective emission reductions, while maintaining 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 available 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 the attainment date by at 
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least one year, then those additional measures are not deemed “reasonably available” 

under EPA policy and do not need to be included in the State Implementation Plan 

(SIP). The evaluation of potential RACM for advancing the attainment date is presented 

in three steps as documented below. 

Step 1: The list of local control measures developed for the 8-Hour Ozone Plan was 

reviewed. Documentation for development of the list of control measures 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 potential local RACM; in total, over 65 documents were 

referenced in developing the list of control measures for consideration. 

Additionally, for the PM2.5 plan development, the PM2.5 Implementation Rule was 

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

would result in additional measures for consideration. It should be noted that EPA has 

not established mandatory measures for all 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 already 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 RACM analysis dated December 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 strategies to review. Some areas are not 

proceeding with SIP development since the EPA PM2.5 implementation rule has been 

comprehensively challenged by the environmental 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 reviewed to see if any additional RACMs 

had been identified. This AQMP combines regulations 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 control 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 Measures (TCM) in the final 

AQMP were taken from the 2004 RTP and 2006 RTIP. Thus, these were previously 

reviewed during the original analysis of RACMs in the SJV 8-hour final Ozone SIP. 

While the South Coast AQMP identified numerous TCMs, they were all specific to 

individual transportation projects in their 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. 
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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 (all categories), New Jersey identified 26 TCMs and onroad 

mobile measures for use in EPA’s RACM analysis review guidelines, 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 Plan, emission reduction estimates were 

developed for the Section 108(f) categories to assess the local RACM list of applicable 

measures. The maximum feasible emission reduction for NOx estimated from 

implementing all of those TCMs was approximately 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 the 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 Regional Particulate Air Quality 

Study (CRPAQS) found that reductions in NOx emissions are more effective in reducing 

secondary ammonium nitrate aerosol concentrations. Similarly, the control measures 

selected in the SIP have focused on NOx reductions 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 summer than during either the winter or on 

annual average basis when average temperatures are lower. This means that NOx 

reductions estimated for 108(f) measures during summer months provide a 

conservative (i.e., higher or greater) estimate of the reductions that can be expected 

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

Due to the benefits of fleet turnover (i.e., replacement of older scrapped vehicles with 

newer vehicles) and increasingly 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 that 
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TCMs analyzed for the ozone plan are estimated to produce a reduction of roughly 14 

tpd in 2013 (assuming the same level of travel reductions apply in 2013 as did in 2020 

and 2023). 

Step 3: The emission reduction estimates were compared against the attainment 

demonstration information contained in the February 2008 version of the Draft 2008 

PM2.5 Plan to determine if they collectively 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 maximum 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 summer emission rates and annual average values will 

be lower) and falls far short of the 100.5 tpd reduction needed to advance attainment by 

a year, the emission reduction analysis concludes that the TCM categories will not 

advance attainment for the PM2.5 Plan. 

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

identified will not advance attainment by a full year and therefore, no further efforts to 

adopt additional local commitments for the SIP are necessary. 

7.3 SUMMARY OF THE STATE STRATEGY 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 new emission reductions needed to bring areas 

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

The commitment for 2014 in the state strategy includes reductions needed to attain the 

PM2.5 standards and provide progress towards meeting the ozone standard. 

Through the public consultation process described below, ARB staff obtained input on 

California’s State Implementation Plan (SIP) efforts. In October 2006, ARB staff held a 

SIP Symposium, followed by a workshop in November to discuss development of 

potential control concepts for meeting the federal 8-hour ozone and PM2.5 standards. 

In January 2007, ARB staff circulated for public review, the Draft Air Resources Board’s 

Proposed State Strategy for California’s 2007 State Implementation Plan (Proposed 

State Strategy) and, in April 2007, conducted 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 conducted 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, the Board directed staff to work with the 

San Joaquin Valley APCD to identify additional measures to achieve emission 

reductions sooner in the Valley. As a result, in September 2007, the Board adopted the 

Revised Proposed State Strategy. The Revised State Strategy includes the 

April 26, 2007 total emission reduction commitments to be accomplished by 2014 for 
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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 are shown in Table 7-3. The San Joaquin 

Valley is relying on NOx, direct PM2.5, and SO2 emission reductions to demonstrate 

attainment of the PM2.5 NAAQS; the state measures emphasize NOx and direct PM2.5 

reductions. This section also includes short descriptions of the measures currently 

under evaluation by ARB staff. 

Table 7-3 Expected Emission Reductions 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 Recreational Boats 0.1 1.3 -- -- 

 Expanded Off-Road Rec. Vehicle Emission Standards -- 2.2 -- -- 

 Additional Evaporative Emission 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 Automotive Repair. DPR = Dept. of Pesticide Regulation 

Locomotives measure relies on U.S. EPA rulemaking and industry agreement to accelerate fleet turnover. 

Note: Emission reductions reflect the combined impact of regulations and supportive incentive programs. 

Emission reduction estimates for each proposed measure are shown for informational purposes only. 

Actual emission reductions from any particular measure may be greater than or less than the amounts 

shown. 
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Overview of the 2007 Statewide Strategy

Responsibility for implementing emission reduction 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 standards and certifying vapor recovery systems, 

providing technical support to the districts, and overseeing local 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. 

In the San Joaquin Valley, emission reductions from the existing federal, State, and 

local source control program are not enough to attain the federal standards. 

Consequently, further emission reductions from new measures must be achieved in 

order to meet the emission reduction target. In September 2007, the Board approved 

the State Strategy for California’s 2007 State Implementation Plan. The new measures 

that provide attainment of the PM2.5 standards in the 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/planning/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 ensure 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 that accrue very high mileage on a yearly 

basis. High mileage vehicles tend to have greater deterioration 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 excess particulate matter (PM) emissions. 
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• 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 the 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 motorcycles are subject to high rates of exhaust 

system tampering. 

Expanded Passenger Vehicle Retirement. Increase the number of vehicles that are 

voluntarily retired by implementing a scrappage program for vehicles 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 program 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 include a program for out-of-state trucks operating 

in California. ARB’s roadside heavy-duty vehicle inspection program would be 

expanded to more effectively identify and screen trucks that need emission control 

system repairs. In addition, under the Goods 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 Cleaner 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) that requires older, dirtier engines to be 

replaced with engines reflecting current technologies or retrofitted with emission control 

devices. The measure also includes setting 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 achieve additional NOx reductions, the Surplus 

Off-Road Opt-in for NOx (SOON) program. ARB will continue working with the 

San Joaquin Valley APCD to identify funding for the SOON program.
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Cleaner In-Use Agricultural Equipment. Accelerate the modernization of the 

agricultural equipment fleet used in California, removing older, dirtier equipment from 

service to be replaced with engines reflecting cleaner technologies. Availability of 

incentives along with equipment availability 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 engines and evaporative emission standards. 
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