San Joaquin Valley Unified Air Pollution 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

SJVUAPCD	

 

 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

 Executive Summary 

 2015 Plan for the 1997 PM2.5 Standard 

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San Joaquin Valley Unified Air Pollution Control District April 16, 2015

ES-1 Executive Summary 

 2015 Plan for the 1997 PM2.5 Standard 

Executive Summary 

This plan addresses the federal mandates related to the 1997 PM2.5 National Ambient 

Air Quality Standard (NAAQS, or standard). Building on decades of developing and 

implementing active and effective air pollution control strategies, this plan contains Most 

Stringent Measures (MSM), Best Available Control Measures (BACM), additional 

enforceable commitments for further reductions in emissions, and ensures expeditious 

attainment of the 1997 standard. However, the tortured path that has led to this 

juncture where the San Joaquin Valley has to rewrite the attainment plan for an old 

standard illustrates the need for modernizing the antiquated provisions of the federal 

Clean Air Act (CAA). 

On April 30, 2008, the District adopted the 2008 PM2.5 Plan satisfying all federal 

implementation requirements for 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, the D.C. Circuit Court ruled that EPA erred by solely 

using Clean Air Act Subpart 1 in establishing its PM2.5 implementation rule, without 

consideration of the PM-specific provisions in Subpart 4. In June 2014, EPA then 

classified the Valley as a Moderate nonattainment area under Subpart 4 with an 

attainment date of April 5, 2015. 

In 2012, after implementing much of the commitments in the 2008 PM2.5 Plan, the 

Valley was on the verge of attaining the 1997 PM2.5 standard with an average annual 

concentration of 14.7 μg/m3

 and an average 24-hour concentration of 56.4 μg/m3 at the 

Valley’s historic peak PM2.5 sites in Bakersfield. However, due to the extreme drought, 

stagnation, strong inversions, and historically dry conditions experienced over the winter 

of 2013-2014, attainment was impossible even if the Valley experienced zero PM2.5 

pollution for the last three quarters of 2014. The CAA includes provisions for excluding 

uncontrollable “exceptional events” from a region’s attainment determination, but the 

current EPA framework specifically excludes stagnation and drought conditions. Given 

that attaining the standard in 2015 was physically impossible, the District was compelled 

to submit a formal request for reclassification to Serious nonattainment with a new 

attainment date of December 31, 2015. Unfortunately, the exceptional weather 

conditions experienced in 2013-2014 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 accordance 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 further complicate matters, a few days 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/m3

 annual). 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

ES-2 Executive Summary 

 2015 Plan for the 1997 PM2.5 Standard 

The above actions trigger additional federal mandates that can best be described as 

chaotic, with multiple attainment plans required for the same pollutant with each 

standard requiring a separate attainment plan, leading to multiple overlapping 

requirements and deadlines. These mandates are summarized below: 

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

the 2006 federal PM2.5 standard 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 nonattainment area under 

Subpart 4 for the 2006 federal PM2.5 standard in January 2015. 

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

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

the District as Serious nonattainment. 

 EPA designated the Valley as a Moderate nonattainment area for the 2012 

federal PM2.5 standard effective April 15, 2015. 

 District must first submit a Moderate plan for the 2012 federal PM2.5 standard to 

justify and request reclassification to Serious nonattainment classification within 

18 months of nonattainment designation by EPA. 

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

the 2012 federal PM2.5 standard within 18 months from EPA’s final action to 

classify the District as Serious nonattainment. 

 For each of the standards, the District would have federally mandated attainment 

deadlines of 6 years from designation as a Moderate area, or 10 years from 

designation as a Serious area, and may need to request an extension depending 

on the timing of actions by EPA and mandated deadlines. 

Through the comprehensive attainment 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 (see Figure ES-1). In addition to these much-needed NOx 

reductions, the District’s strategy also reduces direct PM2.5 emissions that not only 

assist the Valley in attaining the standard as expeditiously as possible, but also reduce 

the PM2.5 emissions that pose the greatest health impacts to Valley residents. These 

strategies, including upcoming measures to further reduce emissions from commercial 

charbroilers, reduce highly health-impactful PM2.5 emissions where and when they 

matter most in Valley neighborhoods, and provide health benefits beyond simply 

attaining the federal standard. 
San Joaquin Valley Unified Air Pollution 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 District and the California Air Resources Board (ARB) took 

full advantage of the extensive scientific research and knowledge that has been 

developed to characterize the Valley’s unique air quality chemistry and challenge. The 

District, through the San Joaquin Valleywide Air Pollution Study Agency, participated in 

and contributed to the expenditure of nearly $30 million to support the California 

Regional Particulate Air Quality Study (CRPAQS). This study, and the subsequent 

research built on its foundation, has shed light on the complexity of PM2.5 in the Valley. 

Additionally, recent health studies highlight the associated risks inherent in the complex 

components of PM2.5. Acknowledgement and understanding of this complexity is 

central to the 2015 PM2.5 Plan and was used to form the scientific foundation of this 

plan. 

Using the extensive body of knowledge regarding formation of PM2.5 in the Valley, ARB 

performed Relative Response Factor (RRF) modeling to predict future PM2.5 

concentrations throughout the Valley based on previous methodologies in the 2008 

PM2.5 Plan. This modeling was performed consistent with EPA guidance, and involved 

sophisticated computer modeling and review by a team of technical staff, including 

close coordination with the District. In addition to the modeling by ARB, the District has 

also performed extensive analysis that provides additional supporting evidence that the 

plan will effectively bring the Valley into attainment. Overall, the modeling and 

supporting technical analysis demonstrate that the emissions reductions achieved 

through the plan’s control strategy bring the entire Valley into attainment of the 1997 

federal 24-hour PM2.5 standard by 2018 and annual PM2.5 standard by 2020. 

0

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150

200

250

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2012 2014 2017 2020

Emissions (tons per day)

NOx Emissions PM2.5 Emissions SOx Emissions
San Joaquin Valley Unified Air Pollution 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 stakeholders to offer 

suggestions and comments for improving and strengthening the plan. The District has 

worked closely with these various stakeholders, including its partner agencies ARB and 

EPA, environmental and community advocacy groups, and business representatives to 

share information regarding the plan, and to receive comments and suggestions. 

Numerous opportunities were provided for public input in 2014 during District Governing 

Board public hearings, Citizen’s Advisory Committee public meetings, and 

Environmental Justice Advisory Group public meetings. The District also met with 

interested advocacy and industry representatives throughout the plan development 

process to address specific questions and comments, and solicit further suggestions for 

control strategies. The District held a public workshop for this plan on March 4, 2015 

that outlined the air quality challenges faced by the Valley and potential strategies for 

responding to the challenge. The workshop was held at the District’s offices in 

Modesto, Fresno, and Bakersfield and by webcast, with many participants attending and 

providing feedback during the workshop. 

All of these meetings have provided opportunities for the public to provide verbal 

comments, and written comments have also been accepted throughout development of 

this plan. These comments have been integral to the development of this plan, and 

have been incorporated as appropriate. All significant comments and responses are 

summarized and posted on the District’s website.