UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION IX 

75 Hawthorne Street 

San Francisco, CA 94105-3901 

April 23,20 10 

James Goldstene, Executive Officer 

California Air Resources Board 

1001 I Street, P.O. Box 2815 

Sacramento, CA 958 12 

RE: Adequacy Status of San Joaquin Valley PM2.5 Reasonable Further Progress and Attainment 

Plan Motor Vehicle Emissions Budgets 

Dear Mr. Goldstene: 

We have found adequate for transportation conformity purposes certain motor vehicle 

emissions budgets (MVEBs) in the San Joaquin Valley 2008 PM2.5 Plan ("SJV PM2.5 Plan") as 

adopted by the San Joaquin Valley Air Pollution Control District on April 30,2008 and by the 

California Air Resources Board (CARB) on May 22,2008. As a result of our adequacy finding, 

Metropolitan Planning Organizations (MPOs) in the San Joaquin Valley and the U.S. Department 

of Transportation must use the adequate budgets in future conformity analyses once the finding 

becomes effective. 

CARB submitted the SJV PM2.5 Plan on to EPA on June 30,2008 as a revision to the 

California State Implementation Plan (SIP). The plan includes new control measures and 

demonstrations of reasonable further progress (RFP) and attainment for the 1997 annual and 24- 

hour PM-2.5 national ambient air quality standards. The plan identifies subregional MVEBs, 

applicable for both the annual and 24-hour PM2.5 standard, for each county in the nonattainment 

area for PM2.5 and nitrogen oxides (NO,) for the RFP milestone years of 2009 and 2012 and for 

the attainment year of 2014. We announced receipt of the plan on the Internet on August 19, 

2008, and requested public comment by September 18,2008. We received no comments on the 

budgets and plan during this comment period. 

This letter transmits our decision that the motor vehicle emissions budgets for 2009 and 

2012 as contained in the SJV PM2.5 Plan are adequate for transportation conformity decisions. 

These budgets are consistent with the State's RFP demonstrations for milestone years of 2009 

and 2012, and these budgets are based on control measures that have already been adopted and 

implemented. The budgets also meet the other adequacy criteria, therefore, these budgets meet 

the transportation conformity adequacy criteria found in 40 CFR 93.1 18(e)(4). The adequate 

budgets which apply to both the annual and 24-hour PM2.5, for each county in the nonattainment 

area, are as follows: 

Printed on Recycled Paper 
This letter also transmits our finding that the motor vehicle emissions budgets for the 

attainment year of 201 4 are inadequate for transportation conformity purposes. These 201 4 

budgets include estimated emission reductions associated with a number of commitments for 

future rule adoption. Although these rules, for the most part, have been adopted and in aggregate 

achieve the expected reductions, the State has not yet revised the budgets to reflect the precise 

reductions expected from the adopted rules. Without these revisions, the 2014 budgets in the SJV 

PM2.5 Plan are not precisely quantified or related to the overall emissions inventory and other 

measures and therefore, they do not meet the adequacy criteria found in 40 CFR 93.1 18(e)(4)(iii), 

(iv), and (v). 
We have detailed our adequacy/inadequacy findings in the enclosures. A copy of this 

letter and its enclosures will soon be posted on the Internet at 

http://www.epa.gov/otaq/stateresources/ transconf7adequacy.htm. We will also announce the 

adequacy findings in the Federal Register. The findings will become effective 15 days after the 

Federal Register announcement pursuant to 40 CFR 93.1 18(f). 

If you have any questions regarding these adequacy findings or would like copies of the 

comments received, please contact Kerry Drake at (41 5) 947-41 57 or Frances Wicher at (4 15) 

972-3957. 

Sincerely, n m6 Deborah Jordan 

Director, Air Division 

Enclosure 

cc: Errol Villegas, SJVUAPCD 

Tony Boren, Fresno COG 

Ronald Brummett, Kern COG 

Terri King, Kings COG 

Patricia Taylor, Madera CTC 

Jesse Brown, Merced COG 

Andrew Chesley, SJCOG 

Vince Harris, Stanislaus, COG 

Ted Smalley, Tulare COG 

Sue Kaiser, FHWA 

Ted Matley, FTA 
Enclosure 1: Transportation Conformity Adequacy Review 

Plan (~~ri12008) 

Reviewers: Frances Wicher I Date: 1/15/10 

Control Strategy State Implementation Plan (SIP) Under Review: San Joaquin 

Valley (SJV) 2008 PM2.5 Plan: Reasonable Further Progress and Attainment 

~ov&nor (or designee) &d was 

subject to a public hearing. 

Date of SIP Revision Receipt by EPA: June 2008 

Sec. 93.1 18(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. 

quantified. 

Sec. 93.1 18(e)(4)(iii) 

by CARB's Executive Oficer, James Goldstene, the Governor's designee. The 

transmittal letter indicates that the CARB formally adopted the plan on May 22, 

2008 through a Board Resolution (08-28). CARB released the plan on April 25, 

2008 and requested public comments by May 2 1,2008 or at the public hearing 

held on May 22,2009. The plan relies upon reduction cornrnitments.fkom the 2007 

State Strategy, which was previously submitted to EPA as a SIP revision on 

November 16,2007. CARB released the 2007 State Strategy on April 26,2007 

The motor vehicle emission budgets 

are clearly identified and precisely 

and May 7,2007 and requested public comments by the public hearing held on 

September 27,2007. 

Consultation with federal, state and local agencies was undertaken; this 

consultation 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 San Joaquin Valley 

Unified Air Pollution Control District (SJWAPCD), and each county's 

Metropolitan Planning Organization (GO). EPA received a copy of the draft 

SJV 2008 PM2.5 Plan and draft State Strategy but provided no written comments. 

The motor vehicle emissions budgets for 2009 and 2012 are clearly identified and 

precisely quantified on page 7-8 of the plan and in Appendix C. These budgets 

reflect control measures that were already adopted and implemented at the time the 

SJVAPCD adopted the plan on April 30,2008. The budgets for 2014 are not 

precisely quantified because they reflect CARB's commitments to reduce 

emissions of PM2.5 and NOx in the SJV. While CARB (and the California 

Bureau of Automotive Repair (BAR)) has now adopted rules to achieve these 

reductions, it has not revised the 2014 budgets to reflect the precise emissions 
Sec. 93.1 18(e)(4)(iv) 

- 

Sec. 93.118(e)(4)(v) 

I 

Sec. 93.1 18(e)(4)(vi) 

YIN 

YI N 

NIA 

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. 

The plan shows a clear relationship 

among the emissions budget@), 

control measures and the total 

emissions inventory. 

Revisions to previously submitted 

control strategy or maintenance plans 

explain and document any changes to 

reductions expected fi-om each of these rules. 

EPA has preliminarily concluded that the budgets for the years 2009 and 20 12, 

when considered together with all other emission sources, are consistent with the 

requirement to demonstrate reasonable further progress for the annual and 24-hour 

PM2.5 standards. This finding is based on review of the plan's RFP 

demonstrations in Chapter 8 which show a generally linear reduction in emissions 

as required by EPA's PM2.5 implementation rule (See 40 CFR 5 1.1009). Other 

relevant materials include the District's control measure strategy in chapter 6 of 

the SJV PM2.5 Plan. The attainment year 2014 motor vehicle emissions budgets 

reflect emission reductions fi-om CAFE3 commitments to achieve PM2.5 and NOx 

reductions in the SJV and not fi-om specified control measures that have been 

drafted or adopted in regulatory form. As discussed before, CAFE3 (and BAR) 

have adopted rules that will achieve these reductions but has not yet revised the 

budgets to reflect the precise emissions reductions expected fi-om each of the 

adopted rules. 

The MVEBs for PM2.5 do not include emissions fi-om re-entrained road dust 

(paved and unpaved) or roadltransit construction activities because neither are 

significant contributors to PM2.5 emissions in the SJV. See SJV PM2.5 plan, pp. 

7-5 & 7-6. 

The SJV PM2.5 Plan includes budgets only for directly emitted PM2.5 and NOx. 

It does not include budgets for the other potential PM2.5 precursors because onroad vehicles are an insignificant contributor to PM2.5 levels in the SJV (sulfur 

dioxide and volatile organic compounds) or controls on them would be ineffective 

at reducing PM2.5 levels in the SJV (ammonia). See SJV PM2.5 plan, pp. 7-4 & 

7-5. 

The emission inventory for all stationary, area, on-road mobile, and nomoad 

mobile sources, and their relation to control measures and the reductions fi-om 

existing measures are described in Appendix A of 2007 State Strategy. The final 

inventories incorporating the reductions fi-om existing measures are given in 

Tables B-1 and B-2 in Appendix B to the SJV 2008 PM2.5 Plan. As stated 

elsewhere, the 20 14 budgets incorporate emissions reduction commitments fi-om 

the State's strategy and the State has not revised the budgets to reflect the 

reductions fi-om measures that have been adopted to fulfill these commitments. 

There are no previously submitted budgets. The SJV 2008 PM2.5 Plan is the first 

plan submitted by California to address PM2.5 standards in the SJV 
The 2008 PM2.5 Plan contains public comments and SJVUAPCD responses in 

appendix J to the plan. Additional verbal comments were received during the 

adoption public hearings held by the SJVUAPCD and CARB and are also 

included as attachments to the November 2007 SIP submittal. We have reviewed 

the compilation of comments and responses and find the responses to be 

acceptable. No issues that might have affected our adequacy finding remain 

unanswered. 

Sec. 93.1 18(e)(5) Y 

any previous submitted budgets and 

control measures; impacts on point 

and area source emissions; any 

changes to established safety margins 

(see 593.10 1 for definition), and 

reasons for the changes (including the 

basis for any changes to emission 

factors or estimates of vehicle miles 

traveled). 

EPA has reviewed the State's 

compilation of public comments and 

response to comments that are 

required to be submitted with any 

implementation plan.