## UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION



# General Technical Support Document for EPA’s Proposed Rule on the 2015 PM 2.5 

# Plan for the San Joaquin Valley For the 1997 PM 2.5 

# 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 Decembe r 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 Practic ability of Attainment ............................. .............. 13
Appendix B: List of SJVUAPCD Rules and SIP Approval s ................................................. ................... 13



## I. Summary
This technical support document (TSD) provides supp lemental information in support of the U.S. Environmental Protection Agency’s (EPA) proposed ru le on revisions to the California State Implementation Plan (SIP) submitted by California A ir Resources Board (“CARB”). These revisions pertain to requirements for fine particulate matter (PM 2.5 

### ) nonattainment areas under part D of title I of the Clean Air Act (CAA, or the “Act”) for the 1997 PM 2.5 

### national ambient air quality standards (NAAQS) in the San Joaquin Valley (SJV).

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

• “2015 Plan for the 1997 PM 2.5 

### Standard,” per letter dated June 25, 2015, from Ri chard 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 PM 2.5 

### 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 a s the “2015 PM 2.5 

### Plan” or the “Plan.”

This TSD is one of three TSDs that accompany our pr oposal on the 2015 PM 2.5 

### 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 Con trol District,” January 2016 (“SJV Rules TSD”), and

• “Technical Support Document for EPA Evaluation of I nterpollutant Trading Ratios in the 2015 San Joaquin PM 2.5 

### Plan,” January 2016 (“Interpollutant Trading Ratio s TSD”).

### 2



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

A. 2011-2013 PM 2.5 

### Design Values (μg/m 3 

### )

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 a nnual average as it had the second highest three-ye ar average. We did not use the site first highest average (Madera-City) co nsistent with the weight of evidence analysis prese nted in the Plan's attainment demonstration.



### B. Ammonia, NO x 

### , and SO x 

### Contributions to Ambient PM 2.5 

### in San Joaquin Valley

Ammonium Nitrate as Component of PM 2.5 Ammonium Sulfate as Component of PM 2.5

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/m 3 ) 7.1 41.3 Ammonium Sulfate Concentration (μg/m 3 ) 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/m 3 ) 5.5 32.0 Sulfate Concentration (μg/m 3 ) 1.8 2.8

Nitrate Proportion of

PM 2.5 31.8% 49.6% Sulfate Proportion of PM 2.5 10.2% 4.4% Ammonium Concentration (μg/m 3 ) 1.6 9.3 Ammonium Concentration (μg/m 3 ) 0.7 1.1

Ammonium Proportion of PM 2.5 9.2% 14.4% Ammonium Proportion of PM 2.5 3.8% 1.6%

### 3

Ammonium Concentration in PM 2.5

Chemical Component Annual Average(BakersfieldPlanz) Winter

Average(BakersfieldCalifornia)

Sum of Ammonium Concentration in PM 2.5 from Ammonium Nitrate and Ammonium Sulfate (μg/m 3 ) 2.3 10.4
Total Ammonium Proportion of PM 2.5 13.0% 16.0%



### C. VOC Contribution to Ambient PM 2.5 

### in San Joaquin Valley

Secondary Organic Aerosol (SOA) as Component of PM 2.5 (Winter Average Only)

Chemical Component Winter Average(BakersfieldCalifornia) Winter Average

(Fresno-Winery)
Organic Matter Proportion of PM 2.5 18% 30%
SOA Proportion of Organic Matter 5% 5%
SOA Proportion of PM 2.5 0.9% 1.5%
2011-2013 Design Value (μg/m 3 ) 64.6 63.5
SOA Contribution (μg/m 3 ) 0.58 0.95

Note for sections II.B and C of this TSD: The chemical composition data presented in the 2015 PM 2.5 Plan was based on 2010-2012 data for the annual av erage and 2011-2013 for the peak day 24-hour average. Given that the at tainment demonstration relies on 2011-2013 base yea r design values, we applied the chemical composition data from 2010-2012 to the 201 1-2013 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 PM 2.5 Plan, Chapter 4, Table 4-3, p. 4-9.

2015 PM 2.5 Plan, Appendix A, Tables A-3 to A-6, pp. A-7 to A- 9.

2015 PM 2.5 Plan, CARB Staff Report, Appendix A, Figures 6 and 7, pp. A-16.

### 4



## III. Analysis of Practicability of Attainment by Decembe r 31, 2015
This section of our TSD explains the methodology us ed by EPA to evaluate CARB’s and the District’s demonstration that the San Joaquin Valley (SJV) Ser ious nonattainment area cannot practicably attain the 1997 PM 2.5 

### NAAQS (annual and 24-hour) by December 31, 2015, w hich 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, PM 2.5 

### 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 PM 2.5 

### NAAQS of 15.0 μg/m 3 

### , the design value is the three-year average of ann ual mean PM 2.5 

### concentrations. Under the rounding conventions of 40 CFR part 50, appendix N, section 4.3, daily PM 2.5 

### values are reported to one decimal place. In compu ting the design value, intermediate calculation results are not rounded; in the final r esult for comparison to the level of the NAAQS, decimals of 0.05 or higher are rounded up. Thus if C x 

### is the annual mean concentration for year x, the 2015 design value D 2015 

### attains the NAAQS when:

D 2015 

### = (C 2013 

### + C 2014 

### + C 2015 

### )/3 ≤ 15.04

which can be restated as:

C 2015 

### ≤ 3 * 15.04 – (C 2013 

### + C 2014 

### )

C 2015 

### represents the maximum 2015 annual mean concentrat ion allowed for attainment, given known annual mean concentrations for 2013 and 2014. EPA c alculated 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 atta inment 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 si tes 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 Ba kersfield-Planz Rd. monitoring site, which would require approximately 95% below the previously reco rded low.

### 5

24-hour NAAQS

For the 24-hour NAAQS of 65 μg/m 3 

### , the design value is the three-year average of ann ual 98th percentile PM 2.5 

### concentrations. Under the rounding conventions of 40 CFR part 50, appendix N, section 4.3, daily PM 2.5 

### values are reported to one decimal place; in calcu lating the design value, intermediate calculation results are not rounded; and in the fin al 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 dai ly PM 2.5 

### value rank is chosen as the 98th percentile; for e xample, if there are between 301 and 350 daily samples collected in a year, then the 7th highest v alue is the 98th percentile. The fewer the number o f samples collected, the higher the rank used ( e.g. 1st high for between 1 and 50 samples). If C x 

### is the 98th percentile concentration for year x, the 2015 desig n value D 2015 

### attains the NAAQS when:

D 2015 

### = (C 2013 

### + C 2014 

### + C 2015 

### )/3 ≤ 65.4

which can be restated as:

C 2015 

### ≤ 3 * 65.4 – (C 2013 

### + C 2014 

### )

C 2015 

### represents the maximum 2015 98th percentile concen tration allowed for attainment, given known 98th percentiles for 2013 and 2014.

EPA calculated these maximum allowed 2015 concentra tions 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 allowe d 2015 98th percentile concentration was substantially lower than has been recorded historic ally. EPA found that Bakersfield-Planz Rd. monitoring site would require a 2015 value approxim ately 44% below the previously recorded low.

Please refer to Appendix A of this TSD, which conta ins 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 derivatio n of the scaling formula used in the 2015 PM 2.5 

### Plan. ( See 2015 PM 2.5 

### 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 = M f 

### - M b 

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



### −   

###   

### = ∆

  

### = %∆ 100

Relative Response Factor or RRF, the ratio of model ed future concentration M f 

### to modeled base year concentration M b 

### :

= 



###  


### Relative sensitivity of the model to emission chang es, 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 pl an, 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 chan ges 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 s ame:

 %∆
%∆ =  %∆′

%∆′

This can be rearranged to:

%∆′
%∆ = %∆′
%∆ = 

! 

### −   ! 

###   ! 

### "





### −   

###   

### " #

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

 

### − 1	 = $ − 1 % × ! 

### −   ! 

###   ! 

### "





### −   

###   

### " #

For the annual standard, the 2008 Plan base and fut ure 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 R RF 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 PM 2.5 

### and for each quarter of the year; they are applied to the corres ponding 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, a s no information is available.

• The District’s non-manufactured home furnace fleet is evenly split among non-weatherized condensing, non-weatherized non-condensing, and wea therized furnaces (1/3, 1/3, 1/3).

• The monthly rate of furnace fleet turnover is const ant.

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

• Annual furnace turnover rate is 5%.

• From the non-weatherized condensing, non-weatherize d non-condensing, and weatherized furnaces, the District assumes emission reductions of 0.105 tpd of NO x 

### in each year starting in 2017, totaling 0.210 tpd by the end of 2018, as use d in the SJV 2015 PM 2.5 

### 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 achi eve 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 mus t comply with the rule’s emission limit during part of the year, while manufacturers of wea therized furnaces may continue to pay a fee.

Calculations:

• Of the 0.105 tpd of NO x 

### estimated of reductions for 2018, we estimate that one third ( i.e. , nine months of sales of non-weatherized condensing furna ces, and three months of sales of nonweatherized non-condensing furnaces) of the Distric t’s estimate of NO x 

### emission reductions for 2018 (0.105 tpd) is creditable under the assumption s listed above, which is 0.035 tpd.

Rule 4696/Commercial Charbroiling Commercial charbroilers are either chain-driven (fo od is automatically moved thorough a cooking device) or are under-fired (food is cooked on a sta tionary 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 charbroil ers be equipped with a catalytic oxidizer with a control efficiency of at least 83% for PM 10 

### and 86% for VOC. Catalytic oxidizers are an effect ive emission control device for these units because the ir semi-enclosed design helps to maintain the hot exhaust stream needed for the catalyst to be effect ive. Identifying cost effective controls for under- fired charbroilers, however, has been challenging.

SJVAPCD previously investigated several controls fo r under-fire charbroilers including high efficiency particulate-arresting filtration systems, electrost atic precipitators, and wet scrubbers and in 2009 concluded these controls were unproven and too cost ly. 2 

### Since 2009, SJVAPCD has allotted $500,000 in incentive funding to retrofit commercial under-fire d charbroilers with VOC/PM 10 

### controls, but received no applications. The District also partnered with S CAQMD, BAAQMD and EPA Region 9 to support University of California at Riverside (UCR) researc h into cost effective controls. To date, UCR has

1 Annual Reductions Total Calculation, “SJVUAPCD Fin al Staff Report - Amendments to Rule 4905,” Page B- 9, Appendix B, submitted April 7, 2015.

2 Final Staff Report for Amendments to Rule 4692, Pa ge 2 and Appendix C, October 8, 2009. SJVAPCD provi des costs ranging from $37,500 to $104,000, with a cost effec tiveness of $22,300 to $58,200 per ton of PM 2.5 reduced.

### 9

tested and provided preliminary results for several technologies including: multiple stage rooftop filtration, in-hood two stage baffle filters, rooft op exhaust conditioning and inertial separation, electrostatic precipitator/activated carbon cells, and ceramic filtration with microwave regeneration. Also, in June 2015, the SJVAPCD Governing Board app roved $750,000 for its Restaurant Charbroiler Technology Partnership program to fund PM control t echnology demonstration projects for under-fired charbroilers at Valley restaurants. 3, 4



### The 2015 PM 2.5 

### Plan includes a commitment by the District to redu ce PM 2.5 

### 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 ach ieved approximately 25% PM reduction and the next lowest was approximately 53% reduction.

3 SJVAPCD Governing Board, Action Summary Minutes, T hursday, June 18, 2015, pages 5-7. http://www.valleyair.org/Board_meetings/GB/agenda_m inutes/Minutes/2015/GB-Minutes_June.pdf

. 4 We note that a recent Manteca “Conditions of Appro val” site plan and minor use permit for a restauran t, 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 contro l 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 PM 2.5 Plan, Appendix C at p. C-119 and SJVUAPCD Governin g 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 PM 2.5 

### Plan for the SJV, including Chapter 6, section 6.5 (“Transportation Conformity”) of the June 25, 2015 submittal and the August 13, 2015 supplemental subm ittal.

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 PM 2.5 Standard (“2015 PM 2.5 Plan” or “Plan”)

, SJVUAPCD (April 16, 2015) were noticed for public hearings by the S JVAPCD and CARB. See San Joaquin Valley Unified Air Pollution Control District (SJVUAPCD) Governing Board Resolution, pag e 4. CARB also provided the required public notice and o pportunity for public comment prior to its May 21, 2015 public hearing on the 2015 PM 2.5 Plan. See April 17, 2015 CARB Notice of Pubic Meeting to Consider Approving the San Joaquin Valle y PM 2.5 State Implementation Plan. CARB provided an opportu nity for public comment prior to and during its May 21, 2015 hearing. The budgets were adopted by CARB on May 21, 2015 and in cluded in a submittal of the 2015 PM 2.5 Plan from CARB to EPA. See letter, Richard Corey, Executive Officer, CARB, to Jared Bl umenfeld, Regional Administrator, EPA Region 9, dated June 25 , 2015, with enclosures, submitting the 2015 PM 2.5 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 PM 2.5 SIP, Plan Supplement (“CARB Plan Supplement”), CARB (June 19, 2015)was publically no ticed by CARB only. CARB’s notice provided the opportunity f or public comment by July 20, 2015, and announced a public he aring on July 23, 2015. See Notice of Pubic Meeting to Consider the Approval of the Transportation Conformity Budgets f or San Joaquin Valley PM 2.5 State Implementation Plan, June 19, 2015. The 2018 budget was adopted by CARB on July 23, 201 5 and included in the submittal of the CARB Plan Suppleme nt 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, s ubmitting the 2015 PM 2.5 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 PM 2.5 Plan was developed through consultation with federal, state and local agencies which took place with the San Joaquin Valley interagency consultation working gro up (the Model Coordinating Committee). Members of the consu ltation group include: EPA, FHWA, FTA, CARB, Caltrans, the SJVUAPCD, and each county’s MPO. The EPA received a copy of the draft 2015 PM 2.5 Plan but did not provided written comments. The EPA verbally commented that the 2015 PM 2.5 Plan including the need for a budget for 2018 (i.e., the attainment year for the PM 2.5 24-hr standard). On July 23, 2015 CARB adopted the CARB Plan Supplement, which included the 2018 budge t. 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 identi fied and precisely quantified in 2015 PM 2.5 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 (s ee 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 emissi on sources are consistent with the requirement to demonstrate reas onable further progress for the 1997 PM 2.5 standards. As discussed in section V.F of EPA’s proposed rule, the EPA is proposing to app rove the RFP demonstration. As discussed in section V.E.2 of EPA’s proposed rul e and section III of this TSD, the EPA is proposing that the Plan demonstrates the impracticability of attainment of the 1997 PM 2.5 standards by the SJV’s currently applicable Moderate area attain ment date of December 31, 2015. As discussed in section V.E.5 of EPA’s proposed rul e, the EPA is proposing to extend the attainment dates to Decembe r 31, 2018 and December 31, 2020 for the 24-hour and annual st andards, respectively. The revised budgets for direct PM 2.5 do not include emissions from re-entrained road dust (paved and unpaved) or road/transit construction activities. The State concluded that n either are significant contributors to PM 2.5 emissions or ambient PM 2.5 levels above the 1997 standard in the SJV. See 2015 SJV PM 2.5 plan, section 6.5.3. The EPA agrees that neither re-entra ined road dust nor road/transit construction activities is a signi ficant contributor to PM 2.5 ambient concentrations in the San Joaquin Valley.
The District considered on-road emissions of PM 2.5 precursors (i.e., SO 2, VOC, and ammonia) and concluded that it’s not necessary to control on-road SO 2, VOC, and ammonia emissions to attain the 1997 PM 2.5 standard. ( id .)

 The Plan does not include budgets for SO 2 because the District indicated in the Plan that on-road vehicle emission s of SO 2 are projected to be an insignificant contributor to PM 2.5 levels. On road mobile exhaust estimates are less than 1 ton p er day (tpd) in the budget years, which equates to less than 8-1 0 percent (depending on the budget year) of the total SO 2 emissions inventory. ( id .) The EPA concurs that it’s not necessary to control on-road SO 2, emissions to attain the 1997 PM 2.5 standard.

 The Plan does not include budgets for VOC because t he District concluded that control of VOC is generally ineffect ive in the control of PM 2.5 and, therefore, VOC is not considered to contribute significantly to elevated PM 2.5 levels in the SJV. ( id .) The EPA concurs that it’s not necessary to control on-road VOC emissions to attain the 1997 PM 2.5 standard. The Plan does not include budgets for ammonia becau se 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 199 7 PM 2.5 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 PM 2.5 , NO x , and other PM 2.5 precursors are described in Appendix B of the 2015 PM 2.5 Plan. Adopted and new control measures are described in C hapter 7 of the 2015 PM 2.5 Plan. The budgets are described in Chapter 6 of th e 2015 PM 2.5 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 2 015 PM 2.5 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 PM 2.5 Plan explains updates to the previous control strategy (i.e., 2008 PM 2.5 Plan), and the changes are reflected in an updated inventory and attainment demonstration. The EPA previously approved 2012 and 2014 budgets in the 20 08 Plan for the 1997 PM 2.5 standards on November 9, 2011 (76 FR 69896, 69923). The 2015 PM 2.5 Plan revises the previously approved 2014 budget and creates 2017, 2018, and 2020 budget s. The changes are primarily due to a new budgets needed f or later years to reflect a new RFP year (2017) and the new attain ment dates (2018 for the 24-hr standard and 2020 for the annua l 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 PM 2.5 Plan contains summaries of the public comments received (both written and oral) and SJVAPCD’s resp onses to all comments in Appendix H to the Plan. The CARB Plan Supplement contains the only public comment receive d (both written and oral) and CARB’s conclusion that the co mment was not relevant. We have reviewed the compilation of c omments and responses. No issues that might have affected our a pproval of the budgets remain unanswered.

### 13 

## Appendix A: Data Worksheets for Analysis of Practic ability of Attainment

• San Joaquin Valley and Practicability of Attaining the 1997 PM 2.5 

### NAAQS by December 31, 2015, dated October 13, 2015 (“Impracticability 201 5 SJV PM 2.5 

### 1997 std 2015-10-13.xlsx”), and

• San Joaquin Valley and Practicability of Attaining the 1997 PM 2.5 

### NAAQS by December 31, 2015, dated January 21, 2016 (“Impracticability 201 5 SJV PM 2.5 

### 1997 std updated 2016-01- 21.xlsx”).



## Appendix B: List of SJVUAPCD Rules and SIP Approval s

• EPA Region 9: Status of San Joaquin Valley Air Poll ution Control District Rules, updated January 22, 2016 (“SJV Rules Tracking 2016-01-22.xl sx”).