UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION IX AIR DIVISION

General Technical Support Document for

EPA’s Proposed Rule on the 

2015 PM2.5 Plan for the San Joaquin Valley 

For the 1997 PM2.5 NAAQS 

Prepared by 

 Region 9 Air Division 

January 2016 
1 

Table of Contents 

I. Summary ......................................................................................................................................... 1

II. EPA Mass-Based Analysis of Precursor Contributions .................................................................. 2

III. Analysis of Practicability of Attainment by December 31, 2015 ................................................... 4

IV. Attainment Demonstration .............................................................................................................. 6

A. Modeling – Derivation of Scaling Formula ..................................................................... 6

B. Control Strategy – SIP Credit Evaluation for Rules 4905 and 4692 ................................ 8

V. Motor Vehicle Emission Budgets Adequacy Evaluation .............................................................. 10

Appendix A: Data Worksheets for Analysis of Practicability of Attainment ........................................... 13

Appendix B: List of SJVUAPCD Rules and SIP Approvals .................................................................... 13

I. Summary 

This technical support document (TSD) provides supplemental information in support of the U.S. 

Environmental Protection Agency’s (EPA) proposed rule on revisions to the California State 

Implementation Plan (SIP) submitted by California Air Resources Board (“CARB”). These revisions 

pertain to requirements for fine particulate matter (PM2.5) nonattainment areas under part D of title I of 

the Clean Air Act (CAA, or the “Act”) for the 1997 PM2.5 national ambient air quality standards 

(NAAQS) in the San Joaquin Valley (SJV). 

The SIP revisions that are the focus of this evaluation are as follows: 

• “2015 Plan for the 1997 PM2.5 Standard,” per letter dated June 25, 2015, from Richard Corey, 

Executive Officer, California Air Resources Board, to Jared Blumenfeld, Regional 

Administrator, EPA Region 9, with enclosures. 

• “2018 Transportation Conformity Budgets for the San Joaquin Valley PM2.5 SIP, Plan 

Supplement,” per letter dated August 13, 2015, from Richard Corey, Executive Officer, 

California Air Resources Board, to Jared Blumenfeld, Regional Administrator, EPA Region 9, 

with enclosures. 

Herein, we refer to these submittals collectively as the “2015 PM2.5 Plan” or the “Plan.” 

This TSD is one of three TSDs that accompany our proposal on the 2015 PM2.5 Plan. The two others are 

as follows: 

• “Technical Support Document for EPA’s Evaluation of Best Available Control Measures and 

Most Stringent Measures for Fine Particulate Matter Emissions from Stationary and Area 

Sources in the San Joaquin Valley Air Pollution Control District,” January 2016 (“SJV Rules 

TSD”), and 

• “Technical Support Document for EPA Evaluation of Interpollutant Trading Ratios in the 2015 

San Joaquin PM2.5 Plan,” January 2016 (“Interpollutant Trading Ratios TSD”). 
2 

II. EPA Mass-Based Analysis of Precursor Contributions 

A. 2011-2013 PM2.5 Design Values (μg/m3) 

Year(s) 

Annual Average 

(Bakersfield-Planz) 

Winter Average 

(BakersfieldCalifornia) Winter Average 

(Fresno-Winery) 

2011 14.5 65.5 67.5 

2012 14.7 56.4 51.3 

2013 22.8 71.8 71.6 

2011-2013 Average 17.3 64.6 63.5 

Note: Bakersfield-Planz is used for the 2011-2013 annual average as it had the second highest three-year average. We did not 

use the site first highest average (Madera-City) consistent with the weight of evidence analysis presented in the Plan's 

attainment demonstration. 

B. Ammonia, NOx, and SOx Contributions to Ambient PM2.5 in San Joaquin Valley 

Ammonium Nitrate as Component of PM2.5 Ammonium Sulfate as Component of PM2.5

Chemical 

Component 

Annual 

Average 

(BakersfieldPlanz) 

Winter 

Average 

(BakersfieldCalifornia) Chemical 

Component 

Annual 

Average 

(BakersfieldPlanz) 

Winter 

Average 

(BakersfieldCalifornia) 

Ammonium Nitrate 

Proportion 41% 64% 

Ammonium Sulfate 

Proportion 14% 6% 

Ammonium Nitrate 

Concentration 

(μg/m3

) 7.1 41.3 

Ammonium Sulfate 

Concentration 

(μg/m3) 2.4 3.9 

Ammonium Nitrate 

Molecular Weight 80.0 80.0 

Ammonium Sulfate 

Molecular Weight 132.0 132.0 

Nitrate Molecular 

Weight 62.0 62.0 

Sulfate Molecular 

Weight 96.0 96.0 

Ammonium 

Molecular Weight 18.0 18.0 

Ammonium 

Molecular Weight 

(two molecules) 36.0 36.0 

Nitrate Proportion 77.5% 77.5% Sulfate Proportion 72.7% 72.7% 

Ammonium 

Proportion 22.5% 22.5% 

Ammonium 

Proportion 27.3% 27.3% 

Nitrate Concentration 

(μg/m3) 5.5 32.0 

Sulfate Concentration 

(μg/m3) 1.8 2.8 

Nitrate Proportion of 

PM2.5 31.8% 49.6% 

Sulfate Proportion of 

PM2.5 10.2% 4.4% 

Ammonium 

Concentration 

(μg/m3

) 

 

1.6 

 

9.3 

Ammonium 

Concentration 

(μg/m3) 

 

0.7 

 

1.1 

Ammonium 

Proportion of PM2.5 9.2% 14.4% 

Ammonium 

Proportion of PM2.5 3.8% 1.6% 
3 

Ammonium Concentration in PM2.5

Chemical Component

Annual 

Average 

(BakersfieldPlanz)

Winter 

Average 

(BakersfieldCalifornia)

Sum of Ammonium Concentration in PM2.5 from 

Ammonium Nitrate and Ammonium Sulfate 

(μg/m3) 

 

2.3 10.4 

Total Ammonium Proportion of PM2.5 13.0% 16.0% 

C. VOC Contribution to Ambient PM2.5 in San Joaquin Valley 

Secondary Organic Aerosol (SOA) as Component of PM2.5 (Winter Average Only) 

Chemical Component 

Winter Average 

(BakersfieldCalifornia) Winter Average 

(Fresno-Winery) 

Organic Matter Proportion of PM2.5 18% 30% 

SOA Proportion of Organic Matter 5% 5% 

SOA Proportion of PM2.5 0.9% 1.5% 

2011-2013 Design Value (μg/m3) 64.6 63.5 

SOA Contribution (μg/m3) 0.58 0.95 

Note for sections II.B and C of this TSD: 

The chemical composition data presented in the 2015 PM2.5 Plan was based on 2010-2012 data for the annual average and 2011-2013 

for the peak day 24-hour average. Given that the attainment demonstration relies on 2011-2013 base year design values, we applied the 

chemical composition data from 2010-2012 to the 2011-2013 annual average, given the absence of annual average chemical 

composition data for 2011-2013. 

Sources for sections II.A, B, and C of this TSD: 

 

2015 PM2.5 Plan, Chapter 4, Table 4-3, p. 4-9. 

2015 PM2.5 Plan, Appendix A, Tables A-3 to A-6, pp. A-7 to A-9. 

2015 PM2.5 Plan, CARB Staff Report, Appendix A, Figures 6 and 7, pp. A-16. 
4 

III. Analysis of Practicability of Attainment by December 31, 2015 

This section of our TSD explains the methodology used by EPA to evaluate CARB’s and the District’s 

demonstration that the San Joaquin Valley (SJV) Serious nonattainment area cannot practicably attain 

the 1997 PM2.5 NAAQS (annual and 24-hour) by December 31, 2015, which requires data primarily 

from the 2013-2015 time period. For this analysis, EPA evaluated air quality data from the following 

sources: 

• Air Quality System (AQS), Quick Look Report AMP450, performed August 8, 2014 (“99-14 QL 

(sites not likely to attain).pdf”), 

• U.S. EPA, 2013 Design Value Reports, PM2.5 Detailed Information, updated August 28, 2014 

(“PM25_DesignValues_20112013_FINAL_08_28_14.xlsx”),

• AQS, Combined Site Values Report AMP355, performed June 30, 2015 (“SJV-2011-2015-

CombSite Rpt-2006ann-std_20150630.pdf”), 

• AQS, Design Value Report AMP480, performed June 30, 2015 (“SJV-2013-2015-DV-Rpt2006std_20150630.pdf”), and 

• AQS, Quick Look Report AMP450, performed August 15, 2015 (“SJV_PM2 5_1998-2015_QL2015-08-15-new.pdf”). 

• AQS, Combined Site Values Report AMP355, performed January 20, 2016 (“SJV-2012-2015-

CombSiteRpt-2006std_20160120.pdf”), and 

• AQS, Design Value Report AMP480, performed January 20, 2016 (“SJV-2012-2015-DVRpt2006std_20160120.pdf”). 

Annual NAAQS 

For the 1997 annual PM2.5 NAAQS of 15.0 μg/m3, the design value is the three-year average of annual 

mean PM2.5 concentrations. Under the rounding conventions of 40 CFR part 50, appendix N, section 4.3, 

daily PM2.5 values are reported to one decimal place. In computing the design value, intermediate 

calculation results are not rounded; in the final result for comparison to the level of the NAAQS, 

decimals of 0.05 or higher are rounded up. Thus if Cx is the annual mean concentration for year x, the 

2015 design value D2015 attains the NAAQS when: 

D2015 = (C2013 + C2014 + C2015)/3 ≤ 15.04 

which can be restated as: 

C2015 ≤ 3 * 15.04 – (C2013 + C2014) 

C2015 represents the maximum 2015 annual mean concentration allowed for attainment, given known 

annual mean concentrations for 2013 and 2014. EPA calculated these maximum allowed 2015 annual 

mean concentrations for SJV monitors, and compared them to the lowest valid annual mean 

concentrations seen since 1999. EPA considered attainment at a monitoring site impracticable if the 

maximum allowed 2015 annual mean concentration was substantially lower than has been recorded 

historically. EPA found that multiple monitoring sites would have to have 2015 annual mean 

concentrations recorded at 35% or more below their corresponding historical lows in order to attain by

the end of 2015. The most extreme example is the Bakersfield-Planz Rd. monitoring site, which would 

require approximately 95% below the previously recorded low. 
5 

24-hour NAAQS 

For the 24-hour NAAQS of 65 μg/m3, the design value is the three-year average of annual 98th 

percentile PM2.5 concentrations. Under the rounding conventions of 40 CFR part 50, appendix N, section 

4.3, daily PM2.5 values are reported to one decimal place; in calculating the design value, intermediate 

calculation results are not rounded; and in the final result for comparison to the level of the NAAQS,

decimals of 0.5 or higher are rounded up. Appendix N section 4.5, table 1 specifies which recorded daily 

PM2.5 value rank is chosen as the 98th percentile; for example, if there are between 301 and 350 daily 

samples collected in a year, then the 7th highest value is the 98th percentile. The fewer the number of 

samples collected, the higher the rank used (e.g. 1st high for between 1 and 50 samples). If Cx is the 98th 

percentile concentration for year x, the 2015 design value D2015 attains the NAAQS when: 

D2015 = (C2013 + C2014 + C2015)/3 ≤ 65.4 

which can be restated as: 

C2015 ≤ 3 * 65.4 – (C2013 + C2014) 

C2015 represents the maximum 2015 98th percentile concentration allowed for attainment, given known 

98th percentiles for 2013 and 2014. 

EPA calculated these maximum allowed 2015 concentrations for selected SJV monitors, and compared 

them to the lowest valid annual mean concentrations seen since 1999. EPA considered attainment at a 

monitoring site impracticable if the maximum allowed 2015 98th percentile concentration was 

substantially lower than has been recorded historically. EPA found that Bakersfield-Planz Rd. 

monitoring site would require a 2015 value approximately 44% below the previously recorded low. 

Please refer to Appendix A of this TSD, which contains the data worksheets upon which this discussion 

is based. 

 
6 

IV. Attainment Demonstration 

A. Modeling – Derivation of Scaling Formula 

This section of our TSD presents a fuller derivation of the scaling formula used in the 2015 PM2.5 Plan. 

(See 2015 PM2.5 Plan, Chapter 4 (“Classification and Attainment”), p. 4-8.). 

Variables and definitions 

b = base year 

f = future year 

E = emissions 

M = modeled concentration 

∆M = change in modeled concentration = Mf - Mb (similar definition for E) 

%∆M = Percent change in modeled concentration M (similar formula for E): 

− 



=

∆



= %∆

100 


Relative Response Factor or RRF, the ratio of modeled future concentration Mf to modeled base year 

concentration Mb: 

 = 	





Relative sensitivity of the model to emission changes, or % change in modeled concentration per % 

change in emissions: 

Sensitivity =

%∆

%∆

Derivation of formula 

The RRF can be expressed in terms of ∆M: 

 = 	





=

− 



+ 1 =

∆



+ 1

so that: 

 − 1 = %∆

100 


Similarly, if modeling had been done for the new plan, its RRF′ would be: 

 − 1 = %∆

100 


giving: 
7 

 − 1

 − 1 =

%∆′

%∆

The assumption we are making in scaling is that the relative sensitivity of the model to emission changes 

from the old plan is the same as what would have been modeled for the current plan, i.e. the percent 

modeled change per percent emission change is the same: 

	

%∆

%∆ = 	

%∆′

%∆′

This can be rearranged to: 

%∆′

%∆ =

%∆′

%∆ 	 =

 



! − !

!

"

 

− 



"

#

The left hand side is the same as above ratio of new and old RRFs, so this gives: 

 − 1	 = $ − 1% ×

 



! − !

!

"

 

− 



"

#

For the annual standard, the 2008 Plan base and future year were b=2005 and f=2014; for the 2015 Plan 

the base and future years are b′=2012 and f′=2020, so: 

'()'*'('(

 − 1	 = $'()+*'((,

 − 1% ×

-

'('( − '()'

'()'

.

-

'()+ − '((,

'((,

.

/

With minor rearrangement, this is the same as the RRF scaling formula given in the 2015 SJV Plan at 

the top of page 4-8. The Plan states it in terms of 1-RRF (rather than RRF-1) because typically future

concentrations are lower, so that RRF < 1 and 1-RRF is a positive number. 

Note that there is actually a separate RRF for each chemical species component of PM2.5 and for each 

quarter of the year; they are applied to the corresponding modeled species concentrations and then 

averaged in the appropriate way to arrive at design values. 
8 

B. Control Strategy – SIP Credit Evaluation for Rules 4905 and 4692 

Rule 4905/Residential Furnaces 

Assumptions: 

The following assumptions were made by EPA staff, as no information is available. 

• The District’s non-manufactured home furnace fleet is evenly split among non-weatherized 

condensing, non-weatherized non-condensing, and weatherized furnaces (1/3, 1/3, 1/3). 

• The monthly rate of furnace fleet turnover is constant. 

The following assumptions are drawn from the District’s staff report. 

• Annual furnace turnover rate is 5%. 

• From the non-weatherized condensing, non-weatherized non-condensing, and weatherized 

furnaces, the District assumes emission reductions of 0.105 tpd of NOx in each year starting in 

2017, totaling 0.210 tpd by the end of 2018, as used in the SJV 2015 PM2.5 Plan. However, it is 

not appropriate to credit reductions in 2017 given that manufacturers may pay a fee in lieu of 

selling only furnaces that comply with the emission limits of the rule and given the absence of an 

adequate demonstration of how those fees would achieve comparable emission reductions.1 

• Due to the way the compliance dates and fee program sunsets are structured in Table 1 of Rule 

4905, manufacturers of non-weatherized furnaces must comply with the rule’s emission limit 

during part of the year, while manufacturers of weatherized furnaces may continue to pay a fee. 

Calculations: 

• Of the 0.105 tpd of NOx estimated of reductions for 2018, we estimate that one third (i.e., nine 

months of sales of non-weatherized condensing furnaces, and three months of sales of nonweatherized non-condensing furnaces) of the District’s estimate of NOx emission reductions for 

2018 (0.105 tpd) is creditable under the assumptions listed above, which is 0.035 tpd. 

Rule 4696/Commercial Charbroiling 

Commercial charbroilers are either chain-driven (food is automatically moved thorough a cooking 

device) or are under-fired (food is cooked on a stationary cooking surface similar to a home barbecue). 

SJVAPCD estimates chain-driven charbroilers account for 42% of its inventory and under-fired for 

58%. Rule 4692 requires that chain-driven charbroilers be equipped with a catalytic oxidizer with a 

control efficiency of at least 83% for PM10 and 86% for VOC. Catalytic oxidizers are an effective 

emission control device for these units because their semi-enclosed design helps to maintain the hot 

exhaust stream needed for the catalyst to be effective. Identifying cost effective controls for under-fired 

charbroilers, however, has been challenging. 

SJVAPCD previously investigated several controls for under-fire charbroilers including high efficiency

particulate-arresting filtration systems, electrostatic precipitators, and wet scrubbers and in 2009 

concluded these controls were unproven and too costly.2 Since 2009, SJVAPCD has allotted $500,000 in 

incentive funding to retrofit commercial under-fired charbroilers with VOC/PM10 controls, but received 

no applications. The District also partnered with SCAQMD, BAAQMD and EPA Region 9 to support 

University of California at Riverside (UCR) research into cost effective controls. To date, UCR has 

 

1

 Annual Reductions Total Calculation, “SJVUAPCD Final Staff Report - Amendments to Rule 4905,” Page B-9, Appendix 

B, submitted April 7, 2015. 

2

 Final Staff Report for Amendments to Rule 4692, Page 2 and Appendix C, October 8, 2009. SJVAPCD provides costs 

ranging from $37,500 to $104,000, with a cost effectiveness of $22,300 to $58,200 per ton of PM2.5 reduced. 
9 

tested and provided preliminary results for several technologies including: multiple stage rooftop 

filtration, in-hood two stage baffle filters, rooftop exhaust conditioning and inertial separation, 

electrostatic precipitator/activated carbon cells, and ceramic filtration with microwave regeneration.

Also, in June 2015, the SJVAPCD Governing Board approved $750,000 for its Restaurant Charbroiler 

Technology Partnership program to fund PM control technology demonstration projects for under-fired 

charbroilers at Valley restaurants.3, 4

 

The 2015 PM2.5 Plan includes a commitment by the District to reduce PM2.5 emissions from charbroilers 

by 20% or 0.4 tpd in Rule 4692.5 We believe this 20% reduction is achievable since preliminary UCR 

tests show the lowest performing control device achieved approximately 25% PM reduction and the next 

lowest was approximately 53% reduction. 

 

3

 SJVAPCD Governing Board, Action Summary Minutes, Thursday, June 18, 2015, pages 5-7. 

http://www.valleyair.org/Board_meetings/GB/agenda_minutes/Minutes/2015/GB-Minutes_June.pdf. 

4

 We note that a recent Manteca “Conditions of Approval” site plan and minor use permit for a restaurant, includes a 

statement that SJVAPCD will amend Rule 4692 in 2016 and strongly recommends requiring new restaurants that will operate 

under-fired charbroilers to install emission control controls during the construction phase. See page 6 item D.3 

http://manteca-ca.granicus.com/MetaViewer.php?view_id=2&event_id=64&meta_id=30949.

5

 2015 PM2.5 Plan, Appendix C at p. C-119 and SJVUAPCD Governing Board Resolution 15-4-7A (April 16, 2015) at 

paragraph 7. 
10 

V. Motor Vehicle Emission Budgets Adequacy Evaluation 

This section of our TSD presents our evaluation the motor vehicle emission budgets in the 2015 PM2.5

Plan for the SJV, including Chapter 6, section 6.5 (“Transportation Conformity”) of the June 25, 2015 

submittal and the August 13, 2015 supplemental submittal. 

Adequacy Review Criteria 

(40 CFR part 93) 

Is 

Criterion 

Satisfied?

Reference in SIP Document/Comments 

Sec. 

93.118(e)(4)(i)

The plan was 

endorsed by the 

Governor (or 

designee) and was 

subject to a public 

hearing.

Y The 2014, 2017, and 2020 budgets in the 2015 Plan for the 1997 

PM2.5 Standard (“2015 PM2.5 Plan” or “Plan”), SJVUAPCD (April 

16, 2015) were noticed for public hearings by the SJVAPCD and 

CARB. See San Joaquin Valley Unified Air Pollution Control 

District (SJVUAPCD) Governing Board Resolution, page 4. 

CARB also provided the required public notice and opportunity 

for public comment prior to its May 21, 2015 public hearing on 

the 2015 PM2.5 Plan. See April 17, 2015 CARB Notice of Pubic 

Meeting to Consider Approving the San Joaquin Valley PM2.5

State Implementation Plan. CARB provided an opportunity for 

public comment prior to and during its May 21, 2015 hearing. The 

budgets were adopted by CARB on May 21, 2015 and included in 

a submittal of the 2015 PM2.5 Plan from CARB to EPA. See letter, 

Richard Corey, Executive Officer, CARB, to Jared Blumenfeld, 

Regional Administrator, EPA Region 9, dated June 25, 2015, with 

enclosures, submitting the 2015 PM2.5 Plan. Also see p.5 of CARB 

Board Resolution 15-9, dated May 21, 2015. 

The 2018 budget the Transportation Conformity Budgets for the 

San Joaquin Valley PM2.5 SIP, Plan Supplement (“CARB Plan 

Supplement”), CARB (June 19, 2015)was publically noticed by 

CARB only. CARB’s notice provided the opportunity for public 

comment by July 20, 2015, and announced a public hearing on 

July 23, 2015. See Notice of Pubic Meeting to Consider the 

Approval of the Transportation Conformity Budgets for San 

Joaquin Valley PM2.5 State Implementation Plan, June 19, 2015. 

The 2018 budget was adopted by CARB on July 23, 2015 and 

included in the submittal of the CARB Plan Supplement from 

CARB to EPA. See letter, Richard Corey, Executive Officer, 

CARB, to Jared Blumenfeld, Regional Administrator, EPA 

Region 9, dated August 13, 2015, with enclosures, submitting the 

2015 PM2.5 Plan. Also CARB Board Resolution 15-39, dated July

23, 2015. 

Sec. 

93.118(e)(4)(ii)

The plan was 

developed through 

consultation with 

federal, state and 

local agencies; full 

implementation 

plan documentation 

was provided and 

EPA’s stated 

concerns, if any, 

were addressed. 

Y The 2015 PM2.5 Plan was developed through consultation with 

federal, state and local agencies which took place with the San 

Joaquin Valley interagency consultation working group (the 

Model Coordinating Committee). Members of the consultation 

group include: EPA, FHWA, FTA, CARB, Caltrans, the 

SJVUAPCD, and each county’s MPO. The EPA received a copy 

of the draft 2015 PM2.5 Plan but did not provided written 

comments. The EPA verbally commented that the 2015 PM2.5 Plan 

including the need for a budget for 2018 (i.e., the attainment year 

for the PM2.5 24-hr standard). On July 23, 2015 CARB adopted the

CARB Plan Supplement, which included the 2018 budget. It was 

subsequently submitted to EPA on August 13, 2015. (id.) 
11 

Sec. 

93.118(e)(4)(iii)

The motor vehicle 

emission budgets 

are clearly 

identified and 

precisely 

quantified. 

Y The 2014, 2017, and 2020 budgets are clearly identified and 

precisely quantified in 2015 PM2.5 Plan (see Section 6.5, pp. 6-16 

and 6-18) and the 2018 budget is clearly identified and precisely 

quantified in the CARB Plan Supplement (see pp. 3 and 6). 

Sec. 

93.118(e)(4)(iv)

The motor vehicle 

emissions 

budget(s), when 

considered together 

with all other 

emission sources, 

is consistent with 

applicable 

requirements for 

reasonable further 

progress and 

attainment.

Y The EPA has concluded that the revised budgets for 2014 and 

2017 when considered together with all other emission sources are 

consistent with the requirement to demonstrate reasonable further 

progress for the 1997 PM2.5 standards. As discussed in section V.F 

of EPA’s proposed rule, the EPA is proposing to approve the RFP 

demonstration. 

As discussed in section V.E.2 of EPA’s proposed rule and section 

III of this TSD, the EPA is proposing that the Plan demonstrates 

the impracticability of attainment of the 1997 PM2.5 standards by 

the SJV’s currently applicable Moderate area attainment date of 

December 31, 2015. 

As discussed in section V.E.5 of EPA’s proposed rule, the EPA is 

proposing to extend the attainment dates to December 31, 2018 

and December 31, 2020 for the 24-hour and annual standards, 

respectively. 

The revised budgets for direct PM2.5 do not include emissions 

from re-entrained road dust (paved and unpaved) or road/transit 

construction activities. The State concluded that neither are 

significant contributors to PM2.5 emissions or ambient PM2.5 levels 

above the 1997 standard in the SJV. See 2015 SJV PM2.5 plan, 

section 6.5.3. The EPA agrees that neither re-entrained road dust 

nor road/transit construction activities is a significant contributor 

to PM2.5 ambient concentrations in the San Joaquin Valley. 

The District considered on-road emissions of PM2.5 precursors 

(i.e., SO2, VOC, and ammonia) and concluded that it’s not 

necessary to control on-road SO2, VOC, and ammonia emissions to 

attain the 1997 PM2.5 standard. (id.) 

 The Plan does not include budgets for SO2 because the District 

indicated in the Plan that on-road vehicle emissions of SO2 are 

projected to be an insignificant contributor to PM2.5 levels. On 

road mobile exhaust estimates are less than 1 ton per day (tpd) 

in the budget years, which equates to less than 8-10 percent 

(depending on the budget year) of the total SO2 emissions 

inventory. (id.) The EPA concurs that it’s not necessary to 

control on-road SO2, emissions to attain the 1997 PM2.5

standard. 

 The Plan does not include budgets for VOC because the District 

concluded that control of VOC is generally ineffective in the 

control of PM2.5 and, therefore, VOC is not considered to 

contribute significantly to elevated PM2.5 levels in the SJV. (id.) 

The EPA concurs that it’s not necessary to control on-road 

VOC emissions to attain the 1997 PM2.5 standard. 

The Plan does not include budgets for ammonia because the 

District indicated in the Plan that on-road mobile exhaust 

estimates of ammonia are approximately 4 tpd in the budget years, 

which equates to about 1 percent or less (depending on the budget 

year) of the total ammonia emissions inventory. (See Appendix B, 

p. B-18 and B-19.) The EPA concurs that it’s not necessary to 
12 

control on-road ammonia emissions to attain the 1997 PM2.5

standard. 

Sec. 

93.118(e)(4)(v)

The plan shows a 

clear relationship 

among the 

emissions 

budget(s), control 

measures and the 

total emissions 

inventory.

Y The emission inventories for all stationary, area, on-road mobile, 

and non-road mobile sources of direct PM2.5, NOx, and other PM2.5

precursors are described in Appendix B of the 2015 PM2.5 Plan. 

Adopted and new control measures are described in Chapter 7 of 

the 2015 PM2.5 Plan. The budgets are described in Chapter 6 of the 

2015 PM2.5 Plan and in the CARB Supplement. The budgets are 

consistent with the inventories in Appendix B that is relied on for 

the attainment demonstration in Appendix F of the 2015 PM2.5

Plan. 

Sec. 

93.118(e)(4)(vi)

Revisions to 

previously 

submitted control 

strategy or 

maintenance plans 

explain and 

document any 

changes to any 

previous submitted 

budgets and control 

measures; impacts 

on point and area 

source emissions; 

any changes to 

established safety 

margins (see 

§93.101 for 

definition), and 

reasons for the 

changes (including 

the basis for any 

changes to 

emission factors or 

estimates of 

vehicle miles 

traveled). 

Y The 2015 PM2.5 Plan explains updates to the previous control 

strategy (i.e., 2008 PM2.5 Plan), and the changes are reflected in an 

updated inventory and attainment demonstration. The EPA 

previously approved 2012 and 2014 budgets in the 2008 Plan for 

the 1997 PM2.5 standards on November 9, 2011 (76 FR 69896, 

69923). The 2015 PM2.5 Plan revises the previously approved 

2014 budget and creates 2017, 2018, and 2020 budgets. The 

changes are primarily due to a new budgets needed for later years 

to reflect a new RFP year (2017) and the new attainment dates 

(2018 for the 24-hr standard and 2020 for the annual standard).

Sec. 

93.118(e)(5)

EPA has reviewed 

the State’s 

compilation of 

public comments 

and response to 

comments that are 

required to be 

submitted with any 

implementation 

plan. 

Y The 2015 PM2.5 Plan contains summaries of the public comments 

received (both written and oral) and SJVAPCD’s responses to all 

comments in Appendix H to the Plan. The CARB Plan 

Supplement contains the only public comment received (both 

written and oral) and CARB’s conclusion that the comment was 

not relevant. We have reviewed the compilation of comments and 

responses. No issues that might have affected our approval of the 

budgets remain unanswered.
13 

Appendix A: Data Worksheets for Analysis of Practicability of 

Attainment 

• San Joaquin Valley and Practicability of Attaining the 1997 PM2.5 NAAQS by December 31, 

2015, dated October 13, 2015 (“Impracticability 2015 SJV PM2.5 1997 std 2015-10-13.xlsx”), 

and 

• San Joaquin Valley and Practicability of Attaining the 1997 PM2.5 NAAQS by December 31, 

2015, dated January 21, 2016 (“Impracticability 2015 SJV PM2.5 1997 std updated 2016-01-

21.xlsx”). 

Appendix B: List of SJVUAPCD Rules and SIP Approvals 

• EPA Region 9: Status of San Joaquin Valley Air Pollution Control District Rules, updated 

January 22, 2016 (“SJV Rules Tracking 2016-01-22.xlsx”).