San Joaquin Valley 

AIR POLLUTION CONTROL DISTRICT HEALTHY 

July 13, 2015 

Jared Blumenfeld 

Regional Administrator 

US EPA Region 9 

75 Hawthorne Street 

Mail Code: ORA-1 

San Francisco, CA 94105 

Richard Corey 

Executive Officer 

California Air Resources Board 

1001 "I" Street 

Sacramento, CA 95814 

RE: Request for EPA Finding that the San Joaquin Valley has Attained the 

Federal 1-hour Ozone Standard 

Dear Mr. Blumenfeld and Mr. Corey: 

The San Joaquin Valley Air District (District) formally requests that the U.S. 

Environmental Protection Agency determine that the San Joaquin Valley (Valley) has 

attained the federal 1-hour ozone standard. Per federal requirements, the attached 

submittal includes a clean data finding and a finding that attainment is due to permanent 

and enforceable emissions reductions. 

Once again, during 2012-2014, the Valley recorded minimal violations of the 1-hour 

ozone standard established by EPA under the federal Clean Air Act. The Valley now 

meets the 1-hour ozone standard based on the most recent three year period air 

monitoring data (2012-2014). 

The 1-hour ozone standard has been the key focus of the Valley's air quality 

management strategies for more than two decades. Since 1992, the District has 

developed and implemented num_erous attainment plans and has adopted over 500 of 

the most stringent rul~s in the natron to obtain the significant emissions reductions 

needed to demonstrate attainment. Additionally, the District has supplemented its 

regulatory programs with a robust voluntary incentive program that has invested over $1 

billion in clean air projects, resulting in over 100,000 tons of emission reductions. The 

Valley will be the first and only region in the nation to attain a standard after being 

classified as "extreme" nonattainment by EPA. The District wishes to express our 

gratitude to EPA, the California Air Resources Board, and other stakeholders in helping 

Valley residents reach this tremendous milestone. 

Northern Regiorl 

4800 Enterprise Way 

Modesto, CA 95356·8718 

Tel: (2091557·6400 FAX: (2091557·6475 

Seyed Sadredin 

Executive Director/Air Pollution Control Officer 

Central Region !Main Officel 

1990 E. Gettysburg Avenue 

fresno, CA 93726·0244 

Tel: (5591230·6000 FAX: 15591230·6061 

www. valley air .org www .healthyairliving.com 

Southern Region 

34946 Flyover Court 

Bakersfield, CA 93308·9725 

Tel: 661·392·5500 FAX: 661·392·5585 

PrlnLedonraeycledpaper Q 
Request for EPA Finding that the San Joaquin Valley has Attained the Federal1-hour Ozone Standard 

July 13, 2015 

Page 2 of 3 

This historic accomplishment reaffirms the effectiveness of the investment and 

commitment by Valley businesses and residents to reduce emissions and improve 

public health. Emissions from stationary sources have been reduced by over 80%, and 

the number of ozone violations in the Valley has consistently dropped over the years. 

Despite strings of triple-digit temperatures and wildfires, 2013 and 2014 were the 

cleanest years on record for ozone: 

• Minimal hours over the 1-hour standard 

• Lowest 8-hour design values 

• Lowest number of 8-hour exceedances 

Tota:l Hours over the 1-hour 03 Standard among 

all Sites per Year 

350 ~------------------------------------------------~ 

~ 300 ·n-------D-----------------------------------------------1 ~ 

ns 

~ 250 +- -- --------------------------------------------1 

ns 

~ 200 -- ;r---------------------------------------------1 ~ 

~ 150 

0 

~ 100 :s 

0 

::E: so 

0 ~~~~~~~~~~~ ~== -- -J 

~~~~~~~~~~~~~~~~~~~ ~~~~~~~~~~~~~~~~~~~ 

Year 

The attached Attainment Determination Request supports both a clean data finding and 

a finding that attainment is due to permanent and enforceable emissions reductions: 

Clean Data Finding: 

• Monitoring data: Air monitoring data from the relevant three-year period (2012-

2014) meets the 1-hour ozone standard via the ~~expected exceedance days" 

test. 

• Monitoring network: As regularly documented in annual monitoring network 

plans, the Valley's ozone monitoring network meets monitoring requirements. 

• .. 
Request for EPA Finding that the San Joaquin Valley has Attained the Federal 1-hour Ozone Standard 

July 13, 2015 

Page 3 of 3 

• Saturation study confirms monitoring approach: A recent saturation study in 

Arvin shows that the current monitoring site location is appropriate. 

Permanent and enforceable emissions reductions: 

• Regulations and emissions reductions: The District and ARB have adopted 

the nation's most stringent regulations, and these regulations achieve significant 

ozone precursor emissions reductions. 

• No unusually favorable meteorology: Meteorological analysis shows that 

2012-2014 ozone season meteorology was neither unusual nor the cause of 

attainment. 

• No decrease in economic activity: Analyses of vehicle miles traveled and state 

fuel sales as indicators of economic activity shows that there wasn't a decrease 

in economic activity that is responsible for attainment. 

Of course, as you know, despite this major achievement, the Valley continues to face 

many air quality challenges in meeting the current and upcoming air quality standards 

for ozone and particulate matter. The District has several air quality plans in place, 

including the 2007 Ozone Plan (for the 1997 8-hour ozone standard), the 2008 and 

2015 PM2.5 Plans (for the 1997 PM2.5 standard), and the 2012 PM2.5 Plan (for the 

2006 PM2.5 standard). The District is also in the early stages of developing attainment 

plans to address the 2008 8-hour ozone standard and the 2012 PM2.5 standard. An 

EPA finding of 1-hour ozone attainment will in no way diminish the intensity and 

magnitude of the work the Valley must continue to do under these plans. Rather, a 

finding of 1-hour ozone attainment will enable the Valley and all of its affected 

stakeholders to better focus its efforts and investments on these upcoming challenges. 

If you have any questions regarding this plan, please contact me or Jon Klassen at 

(559) 230-5800. The District thanks you and your staff for your assistance. 

~eyed 'saetredin 

Executive Director/Air Pollution Control Officer 

Attachments 

Cc: 

Mary D. Nichols, Chairman, California Air Resources Board 

Deborah Jordan, Director, US EPA Region 9 

Kerry Drake, Associate Director, US EPA Region 9 

Kurt Karperos, Deputy Executive Officer, California Air Resources Board