San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

Executive Summary

2015 Plan for the 1997 PM2.5 Standard 

# Executive Summary

2015 Plan for the 1997 PM2.5 Standard SJVUAPCDSan Joaquin Valley Unified Air Polluti on Control District April 16, 2015

Executive Summary

2015 Plan for the 1997 PM2.5 Standard This page intentionally blank.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

ES-1 Executive Summary

2015 Plan for the 1997 PM2.5 Standard 

### Executive Summary

This plan addresses the feder al mandates related to the 1997 PM 2.5 National Ambient Air Quality Standard (NAAQS, or standard). Building on decades of developing and implementing active and effectiv e air pollution control strateg ies, this plan contains Most Stringent Measures (MSM), Best Ava ilable Control Measures (BACM ), additional

enforceable commitments for furt her reductions in emissions, an d ensures expeditious

attainment of the 1997 standard. However, the tortured path th at has led to this juncture where the San Joaquin Va lley has to rewrite the attain ment plan for an old

standard illustrates the need for modernizing the antiquated pr ovisions of the federal Clean Air Act (CAA).

On April 30, 2008, the District adopted the 2008 PM2.5 Plan satisfying all federal implementation requirements fo r the 1997 federal PM2.5 standard . Per guidance from EPA, this plan addressed the 1997 PM2.5 standard under Subpart 1 of CAA Title 1, Part D. Subsequently, in 2013, t he D.C. Circuit Court ruled th at EPA erred by solely using Clean Air Act Subpart 1 in es tablishing its PM2.5 impleme ntation rule, without consideration of the PM-specif ic provisions in Subpart 4. In J une 2014, EPA then classified the Valley as a Moder ate nonattainment area under Su bpart 4 with an attainment date of April 5, 2015.

In 2012, after implementing mu ch of the commitments in the 2008 PM2.5 Plan , the Valley was on the verge of a ttaining the 1997 PM2.5 standard wi th an average annual concentration of 14.7 μg/m 3 and an average 24-hour con centration of 56.4 μg/m 3 at the Valley’s historic peak PM2.5 sit es in Bakersfield. However, du e to the extreme drought, stagnation, strong inversions, and historically dry conditions experienced over the winter of 2013-2014, attainment was impo ssible even if the Valley expe rienced zero PM2.5 pollution for the last three quar ters of 2014. The CAA include s provisions for excluding uncontrollable “exceptional events” from a region’s attainment determination, but the current EPA framework specific ally excludes stagnation and drou ght conditions. Given that attaining the st andard in 2015 was physi cally impossible, the District was compelled to submit a formal request for recl assification to Serious nona ttainment with a new attainment date of December 31, 2015. Unfortunately, the excep tional weather conditions experienced in 2013-2 014 has also made it impossible to meet the new

attainment deadline of December 31, 2015. Therefore, this plan also contains a request

for a one-time extension of the attainment deadline for the 24- hour standard to 2018

and the annual standard to 2020.

Adding further confusion, in a ccordance with federal mandates, in December 2012, the District adopted the 2012 PM2.5 Plan to address the 2006 federal PM2.5 standard. This plan was also adopted under Subpart 1 of the Clean Air Act based on EPA’s guidance at the time. To furt her complicate matters, a few day s before the District adopted the 2012 PM2.5 Plan , EPA proposed a new PM2.5 standard, which was finalized in January 2013 ( 2012 PM2.5 Standard, 12 μg/m 3 annual).San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

ES-2 Executive Summary

2015 Plan for the 1997 PM2.5 Standard The above actions trigger additi onal federal mandates that can best be described as chaotic, with multiple attainmen t plans required for the same p ollutant with each standard requiring a s eparate attainment plan, leading to multi ple overlapping requirements and deadlines. These mandates are summarized belo w:

 EPA classified the District as a Moderate nonattainment area u nder Subpart 4 for

the 2006 federal PM2.5 s tandard in June 2014.

 EPA proposed approval of the District’s 2012 PM2.5 Plan as a Moderate area plan under Subpart 4 in January 2015.

 EPA proposed to reclassify the District as a Serious nonattain ment area under Subpart 4 for the 2006 federal P M2.5 standard in January 2015.

 District must submit a new attainment plan under a Serious cla ssification for the

2006 federal PM2.5 standard within 18 months from EPA’s final a ction to classify

the District as Serious nonattainment.

 EPA designated the Valley as a M oderate nonattainment area for the 2012

federal PM2.5 standard effe ctive April 15, 2015.

 District must first submit a Mode rate plan for the 2012 federa l PM2.5 standard to justify and request reclassificati on to Serious nonattainment c lassification within

18 months of nonattainmen t designation by EPA.

 District must then submit a new attainment plan under a Seriou s classification for

the 2012 federal PM2.5 standard wit hin 18 months from EPA’s fin al action to classify the District as Serious nonattainment.

 For each of the standards, the District would have federally m andated attainment deadlines of 6 years from designa tion as a Moderate area, or 10 years from designation as a Serious area , and may need to request an exten sion depending on the timing of actions by EPA and mandated deadlines.

Through the comprehensive attainm ent strategy included in this 2015 Plan for the 1997 PM2.5 Standard (2015 PM2.5 Plan) , the Valley will reduce NOx emissions by 38% between 2012 and 2020 (s ee Figure ES-1). In addition to these much-needed NOx reductions, the District’s strat egy also reduces direct PM2.5 e missions that not only assist the Valley in attaining the standard as ex peditiously as possible, but also reduce the PM2.5 emissions that pose t he greatest health impacts to Va lley residents. These strategies, including upcoming m easures to further reduce emiss ions from commercial charbroilers, reduce highly health -impactful PM2.5 emissions wh ere and when they matter most in Valley neighborho ods, and provide health benefit s beyond simply attaining the federal standard.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

ES-3 Executive Summary

2015 Plan for the 1997 PM2.5 Standard

Figure ES-1 San Joaquin Valley Emissions Reductions, 2015 PM2. 5 Plan

In developing this plan, the Dist rict and the California Air Re sources Board (ARB) took full advantage of the extensive scientific research and knowled ge that has been developed to characterize the Vall ey’s unique air quality chemi stry and challenge. The District, through the San Joaquin Valleywide Air Pollution Stud y Agency, participated in and contributed to the expenditur e of nearly $30 million to sup port the California Regional Particulate Air Qualit y Study (CRPAQS). This study, a nd the subsequent

research built on its foundation , has shed light on the complex ity of PM2.5 in the Valley. Additionally, recent health studi es highlight the associated ri sks inherent in the complex components of PM2.5. Acknowle dgement and understanding of this complexity is

central to the 2015 PM2.5 Plan and was used to form the sci entific foundation of this plan

.

Using the extensive body of know ledge regarding formation of PM 2.5 in the Valley, ARB performed Relative Response Factor (RRF) modeling to predict fu ture PM2.5 concentrations throughout the Valle y based on previous methodol ogies in the 2008

PM2.5 Plan . This modeling was performed c onsistent with EPA guidance, an d involved sophisticated computer modeling and review by a team of technic al staff, including

close coordination with the Di strict. In addition to the model ing by ARB, the District has also performed extensive analys is that provides additional supp orting evidence that the plan will effectively bring the Valley into attainment. Overal l, the modeling and supporting technical analysis dem onstrate that the emissions re ductions achieved through the plan’s control strat egy bring the entire Valley int o attainment of the 1997

federal 24-hour PM2.5 standard by 2018 and annual PM2.5 standar d by 2020. 0 50 100 150 200 250 300 350

2012 2014 2017 2020Emissions(tonsperday)

NOx Emissions PM2.5 Emissions SOx EmissionsSan Joaquin Valley Unified Air Polluti on Control District April 16, 2015

ES-4 Executive Summary

2015 Plan for the 1997 PM2.5 Standard The 2015 PM2.5 Plan was prepared through an involved public process that provided multiple opportunities for the general public and interested st akeholders to offer suggestions and comments for im proving and strengthening the pl an. The District has worked closely with these various stakeholders, including its p artner agencies ARB and EPA, environmental and community advocacy groups, and business representatives to share information regarding the pl an, and to receive comments a nd suggestions.

Numerous opportunities were pr ovided for public input in 2014 d uring District Governing Board public hearings, Citizen’s Advisory Committee public meet ings, and

Environmental Justice Adviso ry Group public meetings. The Dist rict also met with interested advocacy and industr y representatives throughout the plan development process to address specific questions and comments, and solicit further suggestions for control strategies. The Distric t held a public workshop for th is plan on March 4, 2015 that outlined the air quality c hallenges faced by the Valley an d potential strategies for responding to the challenge. The workshop was held at the Dist rict’s offices in Modesto, Fresno, and Bakersfiel d and by webcast, with many part icipants attending and providing feedback during the workshop.

All of these meetings have pr ovided opportunities for the publi c to provide verbal comments, and written comments have also been accepted througho ut development of this plan. These comments have been integral to the developmen t of this plan, and have been incorporated as appropr iate. All significant comment s and responses are summarized and posted on the District’s website.