San Joaquin Valley Unified Air Pollution Control District

2013 Annual 

Demonstration Report

SIP-Creditability of Emission Reductions Generated through Incentive 

Programs 
San Joaquin Valley Unified Air Pollution Control District January 31, 2014

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Contents 

Executive Summary......................................................................................................... 4

I. Background ............................................................................................................ 5

II. Annual Demonstration Report Elements ................................................................ 7

III. Incentive Program Guidelines ................................................................................ 9

A. District Administered Incentive Programs ............................................................... 9

B. SIP-Creditable Incentive Program Guidelines......................................................... 9

C. ARB Carl Moyer Memorial Air Quality Standards Attainment Program Guidelines13

D. ARB Proposition 1B: Goods Movement Emission Reduction Program Guidelines17

E. USDA NRCS Combustion Systems Improvement of Mobile Engines Incentive 

Program Guidelines..............................................................................................19

IV. Relevant SIP commitments ..................................................................................23

A. SIP Commitments.................................................................................................23

B. Progress/Achievement of SIP Commitments........................................................25

C. SIP Commitment Shortfalls...................................................................................26

V. Monitoring and Enforcement Activities .................................................................27

A. Carl Moyer Program Specific Monitoring and Enforcement Activities ...................28

B. Proposition 1B Program Monitoring and Enforcement Activities............................30

C. Combustion Systems Improvement of Mobile Engines Program Monitoring and 

Enforcement Activities..........................................................................................30

VI. Incentive Program Evaluation ..............................................................................31

VII. Summary Of Emission Reductions And Cost Effectiveness.................................35

Appendix A District Incentive Program Project Information ........................................A-1

Appendix B NRCS Combustion System Improvement Program Project Information..B-1

 

2013 Annual Demonstration Report Data Sheet (electronic attachment) 

 
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EXECUTIVE SUMMARY 

The San Joaquin Valley Unified Air Pollution Control District (District) currently operates 

one of the largest and most well-respected incentive programs in California. Since 1992, 

the District’s incentive programs have provided over $500 million in incentive funds. This 

has been matched by cost-sharing on the part of participating businesses, public 

agencies, and residents, who together have invested over $400 million. These combined 

efforts accelerate the adoption of cleaner technologies (beyond what is achieved by 

stringent regulations alone) to achieve over 100,000 tons of lifetime emission reductions, 

improve air quality, improve public health, and progress the San Joaquin Valley (Valley) 

towards attainment of increasingly stringent federal air quality standards. In addition to 

District-administered incentive programs, the California Air Resources Board (ARB) and 

the United States Department of Agriculture (USDA) Natural Resources Conservation 

Service (NRCS) also implement highly effective incentive programs in the Valley, further 

reducing emissions in the Valley. 

Although incentive programs result in real air quality benefits, the emission reductions 

resulting from voluntary incentive programs have generally not been quantified for or 

provided credit in attainment plans to meet federal Clean Air Act (CAA) requirements. 

District Rule 9610 (State Implementation Plan Credit for Emission Reductions Generated 

through Incentive Programs) serves as an administrative mechanism for crediting 

emission reductions achieved in the Valley through incentive programs for use in state 

implementation plans (SIPs). The future year emission reductions claimed in District SIPs 

through Rule 9610 are to be quantified through annual demonstration reports, such as 

this 2013 Annual Demonstration Report. 

The emission reductions quantified for SIP credit as part of this report are summarized in 

the table below. Extensive documentation of these reductions, related SIP commitments, 

and other Rule 9610 requirements are included in the remainder of this report and in 

supporting data provided in the 2013 Annual Demonstration Report Data Sheet that 

accompanies this report. The emission reductions claimed for SIP credit are accounted 

for in Table 1 below and include reductions of oxides of nitrogen (NOx), particulate matter 

(PM), and reactive organic gases (ROG). 

Table 1: SIP Claimed Incentive-Based Emission Reductions for Future Years 

Pollutant

Emissions Reduced (tons per day) 

2013 2014 2015 2016 2017 2018 2019 2020 

NOx 15.59 12.85 10.90 9.31 6.92 6.68 5.60 3.64 

PM 0.57 0.48 0.44 0.38 0.29 0.28 0.24 0.16 

ROG 1.23 1.03 1.00 0.98 0.97 0.95 0.76 0.50 
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I. BACKGROUND 

In developing the 2007 Ozone Plan, the District and ARB recognized the need for 

additional emission reductions from sources outside of the District’s regulatory authority to 

meet the stringent 1997 8-hour ozone standard, particularly from mobile sources. 

Subsequently, the plan called for significantly increased incentive funding to help 

accelerate attainment of the standard. Since then, the District has advocated to increase 

incentive funding for the Valley, resulting in significantly increased funding the last several 

years. Recognizing the importance of incentive-based emission reductions in addressing 

increasingly stringent federal standards, the District and EPA have been working together 

to develop an administrative framework for providing federal SIP credit for incentive 

programs. 

As part of developing new incentive programs aimed at reducing emissions from 

agricultural equipment, the District and the USDA NRCS collaborated to ensure that both 

agencies’ incentive programs achieve emission reductions that can be credited in SIPs. 

Towards that end, in December 2010, the District, EPA, ARB, and USDA NRCS signed a 

memorandum of understanding (MOU) committing to establish a framework for providing 

such SIP credit. All parties involved (EPA, NRCS, ARB and the District) agreed to work 

collaboratively to develop a mechanism to provide SIP credit for emission reductions from 

federal, state, and local incentive programs that meet the federal criteria of Surplus, 

Quantifiable, Enforceable, and Permanent. 

NRCS and EPA continued to work together to develop a mechanism pursuant to the 

CAA to quantify SIP credit for emission reductions from farm equipment, achieved 

through voluntary incentive programs at the state/local level. As a result of these 

continued efforts, EPA and NRCS signed Implementation Principles for Addressing 

Agricultural Equipment under the Clean Air Act, in July 2012. 

District Rule 9610 is the result of the collaborative efforts between EPA, ARB, NRCS, and 

the District. Rule 9610 provides the District with an administrative mechanism to take SIP 

credit for crediting incentive-based emission reductions achieved in the Valley. The key 

components of the District’s Rule 9610 SIP-crediting process include: 

· Incentive Program Guidelines for specific programs, developed through a public 

process with opportunity for public commenting and EPA concurrence. 

· A Manual of Procedures, which assures that all incentive program guidelines 

used for SIP creditability are publicly available and maintained in a centralized 

location on the District’s website. 

· Annual Demonstration Reports, such as this report, to quantify the amount of 

emissions reductions achieved by incentive programs meeting the requirements in 

Rule 9610. More information on report components and process is included later 

in this report. 
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Throughout the SIP-crediting process, the goal is to quantify incentive-based emission 

reductions that satisfy the following EPA integrity principles (defined in Section 2.0 of Rule 

9610): 

· Surplus: emission reductions are not otherwise required by any federal, state, or 

local regulation or other legal mandate. These emission reductions must also be in 

excess of the baseline inventories underlying a SIP attainment demonstration. 

· Quantifiable: emission reductions can be reliably determined and replicated 

through the use of well-established, publicly available emission factors and 

calculation methodologies. 

· Enforceable: based on the following provisions: 

o The emission reductions must be independently and practicably verifiable 

through inspections, monitoring, and/or other mechanisms; 

o Incentive program violations are defined through legally binding contracts, 

including identifying party or parties responsible for ensuring that emission 

reductions are achieved; 

o Grantees are obligated to provide all records needed to demonstrate that 

emission reductions are achieved; and 

o The public has access to all emission-related information for reductions 

claimed in the annual demonstration report, as outlined in Section 4.0 of 

Rule 9610. 

· Permanent: for the lifetime of the project, assured by actions taken to physically 

destroy, or permanently disable, baseline equipment or vehicles, or to permanently 

amend practices to ensure the reduction of emissions for the duration of the project 

life. 

This report demonstrates that the incentive-based emission reductions quantified and 

claimed for SIP credit meet each of these four integrity principles and complies with 

requirements in Rule 9610. 
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II. ANNUAL DEMONSTRATION REPORT ELEMENTS 

This District-prepared report will demonstrate the quantity of emission reductions 

achieved through SIP-creditable incentive programs. District Rule 9610 includes several 

requirements be met in order to demonstrate that the claimed incentive-based emission 

reductions are SIP-creditable. The elements described in Section 4.0 of Rule 9610 that 

this 2013 Annual Demonstration Report includes are summarized in Table 2. 

Table 2: Annual Demonstration Report Requirements 

Element Where 

satisfied 

Description of guidelines used, how the guidelines ensure that the claimed 

emission reductions are SIP-creditable, and a list of any procedures being 

used for the first time under the rule 

Section III of 

this report 

Quantification of emission reductions generated through incentive programs, 

summarized by pollutant and by years and including: 

· Cost-effectiveness 

· Funding amount 

· Incentive program guideline 

· Project type 

Section VII of 

this report 

Adjustments to reductions claimed in prior annual demonstration reports NA 

Identification of SIP commitments in District adopted SIP(s) which the District 

has satisfied in whole or in part through Rule 9610, including identification and 

quantification of, and remedies for, any shortfalls 

Section IV of 

this report 

Project information, including the following, as applicable: 

· Project identification number 

· Project location 

· Project type 

· Project life 

· Implementation date 

· Funding provided by the District, NRCS, or ARB 

· Guidelines used 

· Quantified emission reductions per year, and aggregated over the 

project life, by pollutant 

· Description of baseline and new equipment 

· Additional details as needed 

Appendices A 

and B of this 

report, Manual 

of Procedures, 

and 2013 

Annual 

Demonstration 

Report Data 

Sheet 

Summary of monitoring and enforcement activities for the reporting period for 

incentive programs for which SIP-creditable emission reductions are being 

claimed, including: 

· Identification of project audits, usage reports, inspections, and other 

monitoring activities 

· List of projects that do not satisfy contractual requirements and 

associated enforcement actions/remedies 

Section V of 

this report 

Incentive Program Evaluation: retrospective assessment of the incentive 

program performance and recommendations, if any, for future enhancements 

Section VI of 

this report 
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Annual Demonstration Report Process 

Section 5.0 of Rule 9610 requires the following process for the annual demonstration 

report: 

1. The APCO shall submit the annual demonstration report and information 

described in Section 4.0 to ARB and EPA no later than August 31 of each year. 

The APCO will present the 2013 Draft Annual Demonstration Report to the District 

Governing Board for review on June 20, 2013. The 2013 annual demonstration report 

will be submitted to ARB and EPA for concurrence after the June Governing Board 

public hearing, and prior to August 31, 2013. 

2. The APCO shall release the draft annual demonstration report to the public and 

present it to the District Governing Board prior to submittal to ARB and EPA for 

concurrence. 

The 2013 Draft Annual Demonstration Report was released to the public for review 

and comment on Tuesday, May 21, 2013. The public comment period ended at 5:00 

PM on Tuesday, June 04, 2013. No comments were received. The public has an 

additional opportunity to comment on the draft report at the June 20, 2013 Governing 

Board public hearing when it will be presented to the Governing Board. 

3. Previously submitted annual demonstration reports shall be made available on 

the District’s website. 

As this is the first annual demonstration report, there are currently no previous 

versions available on the District’s website. However, the rule will be made available 

on the District’s Manual of Procedures website after it has been submitted to ARB and 

EPA for concurrence. 

Recordkeeping Requirements

Section 6.0 of Rule 9610 requires all documents created and/or used in implementing the 

requirements of Section 4.0 shall be kept and maintained as required by the applicable 

incentive program guidelines. Consistent with the California Public Records Act and other 

related requirements, such records shall be made available for public review. The public 

may request records through the District’s Public Records Release Request, available on 

the District website at: 

http://www.valleyair.org/General_info/public_records_release_request.htm. However, the 

records related to implementation of the USDA NRCS Combustion Systems Improvement 

of Mobile Engines incentive program are prohibited from mandatory disclosure pursuant 

to the Federal Food Security Act of 1985 (7 U.S.C. § 608d(2)). 
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III. INCENTIVE PROGRAM GUIDELINES 

A. District Administered Incentive Programs 

Historically, the District has successfully administered a number of incentive programs 

aimed at reducing emissions across a wide variety of sectors in the Valley. These 

programs include: 

· The Heavy-Duty Engine Program: 

o Agricultural tractor/mobile equipment 

o Stationary agricultural irrigation pumps 

o On-road trucks 

o Forklifts 

o Off-road construction equipment 

o Locomotives 

o School buses 

· Proposition 1B: Goods Movement Emission Reduction Program 

o On-road trucks 

o Locomotives 

· Public Benefits Grant Program 

o Light-duty advanced technology vehicles 

o Alternative fuel infrastructure 

o Advanced transit and transportation 

· REMOVE Program 

o Bicycle Infrastructure 

o E-mobility 

o Vanpools 

o Commuter subsidies 

o Alternative fuel vehicle mechanics training 

· Drive Clean! Rebate Program 

· Clean Green Yard Machine Program 

More information about the above mentioned programs is available on the District website 

at: http://www.valleyair.org/Grant_Programs/GrantPrograms.htm. Each of these 

programs is effective in assisting the Valley in reaching our air quality attainment goals 

and the benefits of these programs are reflected in a variety of ways, including advancing 

new technologies, accelerating fleet turnover with the adoption of new technologies, and 

influencing the behavior of Valley residents towards more air-friendly practices. The 

majority of the emissions reduced have been achieved through extremely cost-effective 

heavy-duty equipment replacement, retrofit and repower projects; it is these projects that 

make up the bulk of the claimed emission reductions claimed in this annual demonstration 

report. 

B. SIP-Creditable Incentive Program Guidelines 

Pursuant to Section 4.1 of Rule 9610, the annual demonstration report shall contain a list 

of any incentive program guidelines that are being used to claim SIP credit under this rule 
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for the first time. As this is the first annual demonstration report, all incentive program 

guidelines listed in this report are being used for the first time. That is to say, this is not 

the first time these guidelines are being used, but the first time they are being used to 

claim SIP credit under the administrative mechanism created by Rule 9610. 

Section 3.0 of Rule 9610 provides specific requirements for the District to follow with 

regard to incentive program guidelines. This section of the rule identifies pre-approved 

guidelines, guidelines for which EPA will need to make determinations on before granting 

credit in the SIP, and a requirement for maintaining a website whereby the incentive 

program guidelines are publicly available. 

Section 3.1 of Rule 9610 identifies pre-approved incentive program guidelines from 

which the District can claim credit for incentive-based emission reductions. These 

guidelines include: 

· ARB Carl Moyer Memorial Air Quality Standards Attainment Program (Carl Moyer 

Program) Guidelines for incentive projects funded by either the Carl Moyer Program or 

non Carl Moyer funding sources, for the following project types: 

· On-Road Heavy-Duty Vehicle 

· New Vehicle Purchase (Chapter 1, approved 11/17/2005; Chapter 3, 

approved 2008; or Chapter 4, approved 4/28/2011); 

· Repower (Chapter 1, approved 11/17/2005; Chapter 3, approved 2008; or 

Chapter 4, approved 4/28/2011); or 

· Retrofit (Chapter 1, approved 11/17/2005; Chapter 3, approved 2008; or 

Chapter 4, approved 4/28/2011). 

· On-Road Heavy-Duty Vehicles Fleet Modernization/Replacement (Chapter 2, 

approved 11/17/2005; Chapter 4, approved 3/27/2008; or Chapter 5, approved 

4/28/2011). 

· Off-Road Compression-Ignition Equipment 

· Replacement (Chapter 4, approved 3/27/2008; or Chapter 9, approved 

4/28/2011); 

· Repower (Chapter 5, approved 11/17/2005; Chapter 5, approved 3/27/2008; 

or Chapter 7, approved 4/28/2011); or 

· Retrofit (Chapter 5, approved 11/17/2005; Chapter 5, approved 3/27/2008; 

or Chapter 7, approved 4/28/2011). 

· Portable and Stationary Agricultural Sources 

· Repower (Chapter 10, approved 11/17/2005; Chapter 10, approved 

3/27/2008; or Chapter 10, approved 4/28/2011); 

· New purchase of electric motor (Chapter 10, approved 11/17/2005; Chapter 

10, approved 3/27/2008; or Chapter 10, approved 4/28/2011); or 

· Retrofit (Chapter 10, approved 11/17/2005; Chapter 10, approved 

3/27/2008; or Chapter 10, approved 4/28/2011). 
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· NRCS Conservation Practice Standard 372 - Combustion System Improvement 

(approved September 2010); Conservation Practice Standard 723 – Combustion 

System Air Emission Management (approved May 2009); NRCS General Manual, 

Title 450, Part 401 – Conservation Practice Standards (approved October 18, 2009); 

NRCS General Manual, Title 450, Part 407 – Documentation, Certification, and Spot 

Checking (approved October 17, 2009); Conservation Practice Standard 372 

Specification (approved September 2010); NRCS Interim Conservation Practice 

Standard 723 – Combustion System Air Emission management (approved May 2009); 

and associated NRCS Program Combustion System Improvement of Mobile Engines 

Guidelines for incentive projects funded by EQIP funds and accompanying calculation, 

emission factors, and destruction certification worksheets. 

· ARB Proposition 1B Goods Movement Emission Reduction Program Guidelines for 

Heavy-Duty Diesel Trucks repower, replacement, PM retrofit, or PM + NOx retrofit 

incentive projects funded by Proposition 1B funds or non-Proposition 1B funds. 

Applicable ARB Proposition 1B Goods Movement Emission Reduction Program 

Guidelines are the 2013 Proposition 1B: Goods Movement Emission Reduction 

Program Guidelines (Appendix A, approved 01/25/2013); the 2010 Proposition 1B: 

Goods Movement Emission Reduction Program Guidelines (Appendix A, approved 

03/25/2010); and the 2008 Proposition 1B: Goods Movement Emission Reduction 

Program Guidelines (Appendices A or B, approved 02/28/2008). 

 

The summaries of SIP-creditable incentive-based emission reductions claimed under 

Section 3.1 of Rule 9610 are included in Section VII of this annual demonstration report, 

and the detailed information for each project is presented in the 2013 Annual 

Demonstration Report Data Sheet that accompanies this report. 

Section 3.2 of Rule 9610 allows the District to quantify emission reductions under the rule 

in accordance with incentive program guidelines not specifically identified in Section 3.1, 

provided the District submits to EPA a demonstration that each such incentive program 

guideline provides for SIP-creditable emission reductions. Incentive program guidelines 

subject to Section 3.2 may include ARB Carl Moyer Program Guidelines, NRCS 

Combustion System Improvement Conservation Practice Standard 372 and associated 

NRCS Program Combustion System Improvement of Mobile Engines Guidelines, and 

ARB Proposition 1B Goods Movement Emission Reduction Program Guidelines. Section 

3.2 also allows for SIP-credit for case-by-case determinations under the Carl Moyer 

Program Guidelines if such determination is reviewed through a public process and 

submitted to EPA for approval into the SIP. Any case-by-case determinations that have 

followed the above mentioned process during the report period will be identified in 

section VII of this report. 

The 2013 Annual Demonstration Report employs Section 3.2 of the rule by claiming SIP 

credit for incentive-based emission reductions from the ARB Carl Moyer Program 

Guidelines (2005, 2008, 2011) for locomotive alternative technology switchers and new 

electric forklift purchases. The summaries of these SIP-creditable incentive-based 

emission reductions claimed under Section 3.2 of Rule 9610 are included in Section VI of 
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this annual demonstration report and the detailed information for each project is 

presented in the 2013 Annual Demonstration Report Data Sheet that accompanies this 

report. 

The following discussion demonstrates that each such incentive program guideline 

provides for SIP-creditable emission reductions. 

Locomotive Repower

Projects funded with the 2008 and 2011 Carl Moyer Program Guidelines followed all 

required steps to ensure SIP-creditability criteria were met as follows: 

Surplus – There are currently no federal, state, or local rules or regulations pertaining 

to the emissions of locomotives in the state of California. Therefore, all incentivebased emission reductions are surplus. 

Quantifiable – The Carl Moyer Guidelines provide calculation methodologies and 

emission factors for locomotive projects. These methodologies have been reviewed 

and adopted through a public process. All locomotive projects in this 2013 Annual 

Demonstration Report were quantified using these SIP-creditable calculation 

methodologies, as referenced on the Manual of Procedures website. 

Enforceable – The District performed inspections pursuant to Carl Moyer Guideline 

requirements and satisfied enforceability requirements under Section 4.0 of Rule 

9610. These inspections verified contractual requirements were followed thus 

ensuring projected emission reductions were achieved. These projects included 

legally binding contracts between the grantee and the District that identified the party 

or parties responsible for ensuring that the emission reductions were achieved. These 

contracts also obligated the grantee to provide all records needed to demonstrate the 

emissions reduced. 

Permanent – Per contractual requirements, the cleaner locomotive is required to be 

operated for the duration of the project life. 

Purchase of New Electric Forklifts

Projects funded with the 2008 Carl Moyer Program Guidelines followed all required 

steps to ensure SIP-creditability criteria were met, as follows: 

Surplus – The current regulation for off-road mobile equipment has an exemption for 

agricultural-use vehicles. The forklifts that were funded are used solely for agricultural 

purposes, and therefore are surplus to the state regulation. 

Quantifiable – The Carl Moyer Guidelines provide calculation methodologies and 

emission factors for forklift projects. These methodologies have been reviewed and 

adopted through a public process. All forklift projects in this report were quantified 

using these SIP-creditable calculation methodologies. This methodology assumes the 

baseline equipment to be a new diesel forklift. Therefore, new purchases of electric 
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forklifts are calculated based on the difference in emissions between a new diesel 

forklift and a new electric forklift. 

Enforceable – The District performed inspections pursuant to Carl Moyer Guideline 

requirements and satisfied enforceability requirements under Section 4.0 of Rule 

9610. These inspections verified contractual requirements were followed thus 

ensuring projected emission reductions were achieved. These projects included 

legally binding contracts between the grantee and the District that identified the party 

or parties responsible for ensuring that the emission reductions were achieved. These 

contracts also obligated the grantee to provide all records needed to demonstrate the 

emissions reduced. 

Permanent – Per contractual requirements, the new electric forklift is required to be 

operated for the duration of the project life. 

Section 3.3 of Rule 9610 requires the District to develop and maintain a Manual of 

Procedures that includes all incentive program guidelines used to achieve SIP-creditable 

emission reductions from incentive programs. The rule requires the Manual of 

Procedures be made publicly available on the District’s website and maintained on an 

ongoing basis as incentive program guidelines are adopted and includes a description of 

how incentive program guidelines ensure that emission reductions are SIP-creditable. As 

this is the first annual demonstration report and it is being taken to the District Governing 

Board concurrently with Proposed Rule 9610 and associated documents, the Manual of 

Procedures website is currently available for public viewing in Appendix D of the Final 

Draft Staff Report for Proposed Rule 9610 and is available on the District website at: 

http://www.valleyair.org/Board_meetings/GB/agenda_minutes/Agenda/2013/June/Governi

ngBoardPacketJune2013.pdf. 

Sections C through E below describe the specific incentive program guidelines identified 

in Rule 9610 that were used to reduce emissions and calculate the emission reductions 

included in this annual demonstration report. These guidelines are developed and 

periodically revised in a public process with opportunity for public review and 

commenting. In cases where more than one version of an incentive program guideline 

was used for a given incentive project, the specific version is identified and included 

within the detailed project information provided in the 2013 Annual Demonstration Report 

Data Sheet. Based on EPA guidance and requirements of Rule 9610, the following 

descriptions include details about how each incentive program guideline ensures that the 

EPA integrity principles (also called SIP-creditability criteria) of being surplus, quantifiable, 

enforceable, and permanent are fulfilled. 

C. ARB Carl Moyer Memorial Air Quality Standards Attainment Program Guidelines 

The Carl Moyer Program is a grant program that funds the incremental cost of cleanerthan-required engines and equipment. Adopted in 1999 by ARB, this program was 

created through a public process and provides incentives to help obtain early or extra 
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emission reductions, especially from emission sources in environmental justice 

communities and areas disproportionately impacted by air pollution with a primary 

objective of obtaining cost-effective and surplus emission reductions. 

The Carl Moyer Program has been successfully implemented through the cooperative 

efforts of ARB and air districts in California. As directed by the California Health and 

Safety Code, ARB’s role is to oversee the Carl Moyer Program by managing program 

funds, developing and maintaining guidelines, and determining cost-effectiveness 

methodologies. Air districts use the Carl Moyer Program Guidelines to select, fund, and 

monitor projects in their jurisdiction by providing grants to public and private entities. 

The Carl Moyer Program guidelines include robust administrative requirements to ensure 

that emission reductions are enforceable and are achieved throughout the life of a project. 

The District has used the Carl Moyer Program Guidelines to develop the practices that 

are currently in place to ensure all EPA integrity principles of Surplus, Quantifiable, 

Enforceable, and Permanent are met. The following is a summary of how the Carl Moyer 

Program Guidelines meet each SIP-creditability criterion: 

Surplus 

The Carl Moyer Program Guidelines ensure that projects are surplus to regulations 

by only allowing projects to be selected that are not required by any federal, state, 

or local regulation, memorandum of agreement/understanding with a regulatory 

agency, settlement agreement, mitigation requirement, or other legal mandate. 

For example, the guidelines have accounted for each adopted regulation to 

determine the compliance dates of any affected engines and emission benefits 

claimed by each regulation have been determined. Minimum project lives are 

established in each component to ensure that the program does not fund actions 

taken to comply with regulatory deadlines. The minimum project life requirement 

also ensures the overall cost effectiveness of the program and that the emission 

reductions are real for the life of the project. The summary below provides more 

detail about how the Carl Moyer Program Guidelines ensure that the SIPcreditability integrity principle of “Surplus” is fulfilled: 

o Requirement that emission reductions generated by incentive programs are 

not required by other regulation 

ß (Moyer Guidelines Chapter 2, Project Criteria A, H, I, MM). 

o Protocols for quantifying maximum project life and maximum emission 

reductions which account for upcoming regulatory deadlines for a given 

source category 

ß (Moyer Guidelines Chapter 2, Project Criteria B, I and MM). 

o Assurance that baseline equipment was in use 

ß (Moyer Guidelines Chapter 3, Section Z.6(B) and AA.2.). 

o Assurance that new/upgraded equipment is not already accounted for in 

future-year inventories underlying a SIP attainment demonstration by 

natural fleet turnover, finite equipment life or incentives 

ß The definition of surplus in the Moyer guidelines requires that the 

emission reductions achieved are above and beyond those required 
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under existing regulations that are incorporated into a SIP. As part of 

the SIP development process, ARB reviews the Moyer project mix to 

ensure that the amount of emission reductions credited to the 

program are not included in the future year inventories specific to 

each individual attainment demonstration. 

o Procedures that ensure that old equipment was used in the geographic area 

of interest 

ß (Moyer Guidelines, Chapter 2, Section S and Chapter 3, Section 

Z.6.(B)). 

Quantifiable 

The District evaluates the potential emission reductions that would be achieved by 

replacing the old equipment with the new equipment using the established 

calculation methodologies and emissions factors in the program guidelines. The 

calculation methodology, including calculation formulas, assumptions, emission 

factors and sample calculations are part of the Carl Moyer Program Guidelines and 

have been approved through a public process. To ensure that real, quantifiable 

emission reductions are achieved over the life of a project, the program guidelines 

require that emission control technologies be certified or verified by ARB 

(certification or verification by the EPA or International Maritime Organization may 

be allowed for some source categories for which ARB does not have a certification 

or verification program). The summary below provides more detail about how the 

Carl Moyer Program Guidelines ensure that the SIP-creditability integrity principle 

of “Quantifiable” is fulfilled: 

· Emissions data needed to calculate emission reductions must be 

publicly available, current, and accurate. This should include 

appropriate emission factors, load factors, and other conversion factors. 

o Moyer Guidelines, Appendix D (Publicly Available) and Chapter 1, 

Section E.7 (Allows ARB Executive Officer to modify the 

Guidelines under a public process, to keep them effective and upto-date.) 

· Guidelines include necessary formulas and instructions to calculate 

emission reductions based on above data, and explicit instructions to 

ensure appropriate data are used in calculations 

o Moyer Guidelines, Appendix C (contains formulas and 

instructions) 

o Moyer Guidelines, Supplemental document, “Sample 

Calculations” (contains formulas and instructions) 

o Moyer Guidelines, Appendix C, Section B.5, and Supplemental 

document, “Sample Calculations” (contains explicit instructions 

regarding inputs) 

· Requirement to provide activity data sufficient to determine actual 

emission reductions 

o Moyer Guidelines, Chapter 3, Section Z.6.(B) 
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 SIP Credit for Emission Reductions Generated Through Incentive Programs 

· Requirement to demonstrate the percentage of emission reductions that 

occur in the geographic area of interest, and that emission reductions 

are therefore SIP creditable 

o Moyer Guidelines, Section S. 

o Moyer Guidelines, Section Z.6.(B) 

· Requirement to periodically audit completed projects to verify emission 

reduction projections are fulfilled 

o Moyer Guidelines Chapter 2, Sections Z.10. 

o Moyer Guidelines Chapter 3, Sections EE. 

Enforceable 

Emission reductions and other required actions are enforceable if: they are 

independently verifiable; program violations and those liable are defined; information 

needed to determine emission reductions is available to the public; and they are 

practicably enforceable in accordance with other EPA guidance on practicable 

enforceability. The summary below provides more detail about how the Carl Moyer 

Program Guidelines ensure that the SIP-creditability integrity principle of “Enforceable” 

is fulfilled: 

· Require Grantees to provide all necessary recordkeeping and reporting 

needed to verify emission reductions 

o Moyer Guidelines, Chapter 3, Section Z.9 and DD 

· Require inspections to ensure incentive program information is 

consistent with actual operating equipment 

o Moyer Guidelines Chapter 3, Sections AA and BB. 

· Identify liable parties and liability associated with contract 

noncompliance 

o Moyer Guidelines Chapter 3, Section Z.11. 

Permanent 

To ensure that the SIP-creditable emission reductions are permanent, actions such 

as pre-inspections and post-inspections of the new equipment and verification that 

the baseline equipment has been destroyed through the required process as 

described in the program guidelines are performed. The summary below provides 

more detail about how the Carl Moyer Program Guidelines ensure that the SIPcreditability integrity principle of “Permanent” is fulfilled: 

· Data needed to determine and track location of activity 

o Moyer Guidelines, Chapter 3, Section DD 

· Provisions for ensuring that the project was completed, including the verification 

of disposition of baseline equipment. 

o Moyer Guidelines Chapter 3, Sections AA and BB 

A summary of emission reductions achieved through the use of the Carl Moyer Program 

Guidelines is included in Section VII of this report. The complete Carl Moyer Program 

Guidelines can be found online at: www.arb.ca.gov/msprog/moyer/guidelines/current.htm. 
San Joaquin Valley Unified Air Pollution Control District January 31, 2014

Page 17 2013 Annual Demonstration Report 

 SIP Credit for Emission Reductions Generated Through Incentive Programs 

D. ARB Proposition 1B: Goods Movement Emission Reduction Program 

Guidelines 

In November 2006, California voters approved Proposition 1B authorizing $1 billion in 

bond funding to reduce air pollution associated with the movement of freight along 

California’s major trade corridors. Subsequent implementing legislation established 

standards and procedures for the expenditure of these funds. Governor 

Schwarzenegger’s Executive Order S-02-07 provides further direction to ensure 

accountability and transparency in administering bond-funded programs. 

ARB developed the Proposition 1B: Goods Movement Emission Reduction Program 

Guidelines for Implementation (Proposition 1B Guidelines),through a public process in 

consultation with stakeholders, including: air districts, metropolitan planning 

organizations, port authorities, shipping lines, railroad companies, trucking companies, 

harbor craft owners, freight distributors, terminal operators, local port community advisory 

groups, community interest groups, and airports. 

The Proposition 1B Guidelines ensure that the District funds qualifying projects that 

achieve the following results: 

· Reduce emissions and health risks; 

· Incorporate simplicity and efficiency; 

· Ensure cost effectiveness; 

· Leverage other funding sources; and 

· Provide transparency and accountability.

ARB, under direction from Executive Order S-02-07, established transparency and 

accountability measures for administering the bond funding. ARB has made all program 

materials including, but not limited to; guidelines, Board Resolutions, Notice of Funding 

Availability, summary tables, recommendations for funding, materials from public 

workshops, and completed applications submitted by local and state agencies available 

on their website. 

Through the Proposition 1B Program, the District provides incentive funds to reduce 

emissions from eligible heavy-duty trucks traveling through California’s major trade 

corridors and locomotives with the following funding options: 

· Retrofit of existing vehicles 

· Repower of existing vehicles 

· Replace an older vehicle with a newer, cleaner vehicle 

· A tiered truck transaction, which involves retrofitting and replacing two different 

vehicles. 

The program is designed to supplement ARB’s diesel regulations by funding early 

compliance or providing extra emission reductions beyond those required by current 

rules. 
San Joaquin Valley Unified Air Pollution Control District January 31, 2014

Page 18 2013 Annual Demonstration Report 

 SIP Credit for Emission Reductions Generated Through Incentive Programs 

The guidelines include robust administrative requirements to ensure that emission 

reductions are enforceable and are achieved throughout the life of a project. The District 

has used the Proposition 1B Guidelines to develop the practices that are currently in 

place to ensure all EPA integrity principles are met. The following is a summary of how 

the Proposition 1B Guidelines meet each SIP-creditability criterion: 

Surplus 

The Proposition 1B program supplements ARB’s diesel regulations by funding 

early compliance or providing extra emission reductions beyond those required by 

current rules. The program guidelines require that the District ensure all trucks 

being considered to receive funding have had ARB verify compliance with the 

state’s diesel regulations and further require that any trucks under contract with the 

District be noted as such in the state’s online regulation reporting database. This 

ensures that the new truck will not be used towards compliance during the project 

life ensuring that the emission reductions are surplus. Chapter 6 Section E 

discusses the requirements that fleets remain in compliance with the Truck and 

Bus Regulation and that program funded equipment cannot be used towards 

compliance with the regulation. 

Quantifiable 

The District evaluates the potential reductions that would be achieved by replacing 

the old equipment with the new equipment using the Project Benefits Calculator 

created by ARB. The calculator is available to the public on ARB’s website at 

http://www.arb.ca.gov/bonds/gmbond/gmbond.htm and is updated by ARB on a 

regular basis. Chapter 2 Section C Discusses Proposition 1B program emission 

reduction calculations. 

Enforceable 

The District has created enforceable contracts, based on requirements in the 

Proposition 1B Program guidelines, which are signed by both District management 

and the Grantee to ensure that projects are fully accomplished and the integrity 

principles are met. The legally binding contracts include, but are not limited to, 

usage reporting requirements for the Grantee, operating location requirements for 

the new vehicle, the destruction requirements of the baseline equipment/engine, 

and an allowance for the District to conduct an audit of the project at any time 

during the project life. Appendix A of Proposition 1B Program guidelines details 

contract requirements for truck projects. 

Permanent 

To ensure that the SIP-creditable emission reductions are permanent, actions such 

as post-inspections of the new equipment and verification that the baseline 

equipment has been destroyed through the required process as described in the 

program guidelines are performed. Chapter 4 Section A of the Proposition 1B 

program discusses scrap and post inspection requirements. 

A summary of emission reductions achieved through the use of the Proposition 1B 

Program Guidelines is included in Section VII of this report. The complete Proposition 1B 
San Joaquin Valley Unified Air Pollution Control District January 31, 2014

Page 19 2013 Annual Demonstration Report 

 SIP Credit for Emission Reductions Generated Through Incentive Programs 

Program Guidelines can be found online at: 

http://www.arb.ca.gov/bonds/gmbond/gmbond.htm. 

E. USDA NRCS Combustion Systems Improvement of Mobile Engines Incentive 

Program Guidelines 

Under the Food Conservation and Energy Act of 2008, the USDA Secretary provides eligible 

producers with program support to address serious air quality concerns from agricultural 

operations and help meet regulatory requirements through the Environmental Quality 

Incentives Program (EQIP). The National Air Quality Initiative (NAQI, once referred to as 

“CIG-b”) is a voluntary incentive program with the primarily goal to achieve and maintain the 

health-based National Ambient Air Quality Standards (NAAQS) within designated nonattainment areas of California. Financial assistance is targeted to counties that have been 

identified as having significant air quality resource concerns by being designated as nonattainment for Ozone and/or Particulate Matter (PM10 / PM2.5). These areas experience air 

pollution levels that persistently exceed the NAAQS established by the CAA.

http://www.ca.nrcs.usda.gov/programs/eqip/2013/2013_air_quality_initiative.html

Given its experience in running similar incentive programs, the District provided 

assistance to NRCS in developing this new program. Through this program, NRCS 

provides incentive funds to assist farmers in replacing diesel powered agricultural 

equipment with the goal of ensuring the resulting emission reductions meet the SIPcreditability criteria of being surplus, quantifiable, enforceable, and permanent. Since 

2009, the NRCS program, in combination with the District’s program, has provided over 

$105 million in incentives for agricultural equipment replacement, with significant 

continued investment currently ongoing. Eligible participants are owners of land in 

agricultural or forest production or persons who are engaged in livestock, agriculture, or 

forest production on eligible land and that have a natural resource concern on the land. 

Applications are accepted on a continuous basis with periodic application ranking cut-offs. 

The NRCS has specific expertise regarding agricultural practices and operations and 

works closely with agricultural stakeholders in reviewing applications for eligibility. 

Applications are ranked for funding based upon ranking criteria developed with input from 

Local Work Groups, Stakeholders, and the State Technical Advisory Committee (STAC). 

The ranking score of a project is based on multiple factors including but not limited to: 

· Whether or not the project location is in an area that has an EPA NAAQS nonattainment designation for PM2.5, PM10, and/or Ozone and what type of 

designation that area has (for example “extreme” nonattainment). 

· If there are currently any local or state agriculturally based air emission regulatory 

requirements for the area that the project is located. 

· The emission level of the baseline equipment/engine and the emission factors of 

the new/replacement equipment/engine. 

· The amount of NOx, ROG, and PM that is projected to be reduced by funding the 

project. 
San Joaquin Valley Unified Air Pollution Control District January 31, 2014

Page 20 2013 Annual Demonstration Report 

 SIP Credit for Emission Reductions Generated Through Incentive Programs 

The ranking criteria ensure that the projects with the greatest amount of reductions, 

resulting in the highest air quality benefit will be selected for funding. 

NRCS has created robust administrative requirements based on those in the Carl Moyer 

Program Guidelines to ensure that emission reductions are enforceable, are achieved 

throughout the life of a project, and ensure all EPA integrity principles are met. These 

requirements are contained in Conservation Practice Standard (CPS) 372 – Combustion 

System Improvement and associated specifications and procedures. The following is a 

summary of how the NRCS Guidelines meet each SIP-creditability criterion: 

Surplus 

Under the NAQI, page 3 of the CA-NRCS program guidelines specifies that SIP 

creditable emission reductions are “achieved from contracts or parts of contracts 

funded under the air quality initiative [that] are not required by any federal, state, or 

local regulation, settlement agreement, mitigation requirement, or other legal 

mandate.” A rule or regulation does not currently exist for off-road mobile 

agricultural equipment, so the emission reductions resulting from replacing existing 

mobile off-road agricultural engines funded under the NAQI per CPS 372- 

Combustion Systems Improvement are surplus. The FY 2013 National Air Quality 

Initiative Programs Description is posted on-line at: ftp://ftpfc.sc.egov.usda.gov/CA/programs/EQIP/2013/2013_EQIP_Air_Quality_Initiative_P

rogDesc.pdf. 

The 2012 CA-NRCS program guidelines are posted on-line at: ftp://ftpfc.sc.egov.usda.gov/CA/programs/AQI/2012_Combustion_Systems_Improvement_

Policy_and_Procedures.pdf

Quantifiable 

The District provided technical assistance to CA-NRCS in developing their 

calculation methodologies. The methodologies from the Carl Moyer Program are 

the basis for components included in CPS-372 and its supporting documents for 

the NAQI, including the CA-NRCS program guidelines. The District provided 

technical assistance to CA-NRCS in developing their calculation methodologies, 

which are consistent with the Carl Moyer Program. The NRCS Field Office 

Technical Guide places a ten-year lifespan for projects implemented under CPS 

372 – Combustion System Improvement, which is also consistent with the Carl 

Moyer program. A conservation practice lifespan is the minimum time (in years) 

the implemented practice is expected to be fully functional for its intended purpose 

(NRCS General Manual, Title 450, Part 401.15) 

http://directives.sc.egov.usda.gov/viewerFS.aspx?hid=19430. A list of California 

NRCS practice standard life-spans are posted on-line at: 

http://efotg.sc.egov.usda.gov/references/public/CA/List_of_Practices_Lifespans_20

12-12_CA_Numeric.xlsx

The emission reductions for each project are calculated using the methodologies 

outlined in the Carl Moyer Guidelines. All equipment engines are cross-referenced 

against an ARB executive order that verifies the emission of every equipment 

engine. The NRCS calculation worksheets and emission factors are posted on-line 
San Joaquin Valley Unified Air Pollution Control District January 31, 2014

Page 21 2013 Annual Demonstration Report 

 SIP Credit for Emission Reductions Generated Through Incentive Programs 

at: ftp://ftpfc.sc.egov.usda.gov/CA/programs/EQIP/2013/2013_EQIP_Air_Quality_Initiative_A

ttachments.pdf 

Enforceable 

The NRCS inspects equipment in proposals prior to contract development to verify 

the existing mobile off-road agricultural equipment is operational per CPS-372 

specifications. Destruction of existing equipment is certified by the disposal 

operator and participant and date-stamped photos are provided. The certification 

worksheet is posted on-line at: ftp://ftpfc.sc.egov.usda.gov/CA/programs/EQIP/2013/2013_EQIP_Air_Quality_Initiative_A

ttachments.pdf. 

On an annual basis NRCS reviews at least 5% of all active projects. From these 

project reviews NRCS verifies that the new equipment is still operational. 

http://directives.sc.egov.usda.gov/RollupViewer.aspx?hid=25728. 

Per Subpart C, 512.22, participants have control of the land for the length of the 

proposed contract through deed, lease, or other written authorization. If the 

applicant does not own the land, the landowner must give written consent to install, 

operate, and maintain the practice through the lifespan of the practice. This is 

conducted through a partnership with the USDA Farm Service Agency, who is 

responsible for program eligibility support. 

Subpart F covers Contract Administration and provides for recovering liquidated 

damages for certain deviations to a contract. Handling contract violations is 

addressed in Subpart H where violations of contract terms must be corrected by 

the participant within a reasonable period of time to comply. If the violation 

continues, the contract may be terminated and future program participation 

deferred. 

Permanent 

NRCS eligibility is based on the county that the tractor resides in; in this case, the 

tractor has to reside within one of the eight counties of the San Joaquin Valley. 

Under the NAQI, the NRCS prioritizes applications based on a county’s nonattainment designation within California. Applications received from attainment 

areas are not eligible. Currently, only the emission reductions originating from 

within the eight San Joaquin Valley counties are seeking SIP credit under this 

proposal. The destruction of the existing mobile off-road engines and equipment 

are verified per CPS 372 specifications, posted on-line at: 

http://efotg.sc.egov.usda.gov/references/public/CA/372-spec-09-2010.doc. 

Destruction certification worksheets are posted on-line at: ftp://ftpfc.sc.egov.usda.gov/CA/programs/EQIP/2013/2013_EQIP_Air_Quality_Initiative_A

ttachments.pdf. The NRCS also has a stipulation that the tractor has to be tied to 

the land where it is in use. This requires that the tractor be used 100% of the time 

in the San Joaquin Valley. Under the NAQI, NRCS staff verifies by site visit the 

operational condition of the existing mobile off-road agricultural equipment. 
San Joaquin Valley Unified Air Pollution Control District January 31, 2014

Page 22 2013 Annual Demonstration Report 

 SIP Credit for Emission Reductions Generated Through Incentive Programs 

Destruction of the existing equipment and emissions certification verifications are 

performed to determine contract compliance. 

The Combustion Systems Improvement of Mobile Engines incentive program is unique 

from other incentive programs in that NRCS is explicitly prohibited from identifying 

Grantees by name. As directed by the Farm Bill (Food Security Act of 1985 (7 U.S.C. § 

608d(2))), NRCS must maintain the confidentiality of information provided by an 

agricultural producer participating in the NRCS Combustion Systems Improvement of 

Mobile Engines incentive program. The information is exempt from mandatory disclosure 

and may not be used in judicial or administrative proceedings without the consent of the 

person involved. 

A summary of emission reductions achieved through the use of the NRCS Combustion 

System Improvement of Mobile Engines incentive program guidelines is included in 

Section VII of this report. The NRCS Combustion System Improvement of Mobile 

Engines incentive program can be found online at: 

· Conservation Practice Standard 372: 

http://efotg.sc.egov.usda.gov/references/public/CA/372-std-09-2010.pdf 

· Conservation Practice Standard 372 Specification: 

http://efotg.sc.egov.usda.gov/references/public/CA/372B-OM-ca-8-13.doc

· Procedures: ftp://ftpfc.sc.egov.usda.gov/CA/programs/AQI/2012_Combustion_Systems_Improvement_

Policy_and_Procedures.pdf
San Joaquin Valley Unified Air Pollution Control District January 31, 2014

Page 23 2013 Annual Demonstration Report 

 SIP Credit for Emission Reductions Generated Through Incentive Programs 

IV. RELEVANT SIP COMMITMENTS 

Through Rule 9610, the District may rely on projections of SIP-creditable incentive-based 

emission reductions to satisfy federal CAA requirements, including the demonstration of 

attainment, Reasonable Further Progress, Rate of Progress, contingency measures, 

and/or black box reductions (Section 182(e)(5) of the CAA). For such SIP commitments, 

the District identifies specific amounts of SIP-creditable emission reductions by year in the 

relevant SIP. This annual demonstration report then identifies the SIP commitments 

included in District adopted SIPs (by year, pollutant, and magnitude) which the District 

has satisfied, in whole or in part, through SIP-creditable emission reductions. This annual 

demonstration report also identifies and quantifies any SIP commitment shortfalls and 

remedies for addressing those shortfalls. 

A. SIP Commitments 

The following table is a summary of SIP commitments to reduce emissions for which the 

District intends to claim credit for using District Rule 9610 as the administrative 

mechanism. The magnitude of the emission reductions are expressed in tons per day 

(tpd). 

Table 3: Relevant Commitments in District-adopted SIPs 

District-adopted 

SIP 

Adoption 

date 

Requirement Year Pollutant Magnitude

2008 PM2.5 Plan 

Anticipated 

6/20/13 Contingency1

2015 NOx 

PM2.5 

4.15 tpd 

0.10 tpd 

2007 Ozone Plan 9/27/07 

ARB commitment 

to reduce ag 

equipment 

emissions2

2017 NOx 5-10 tpd 

2007 Ozone Plan 4/30/07 “Black Box” 20233 NOx TBD 

2012 PM2.5 Plan 12/20/12 Contingency4

2020 NOx 1.9tpd 

 

1

SJVUAPCD, 2008 PM2.5 Plan (April 30, 2008). Retrieved May 2013 at 

http://www.valleyair.org/Air_Quality_Plans/docs/AQ_Final_Adopted_PM2.5/13%20Chapter%209.pdf

2

 ARB, 2007 State Strategy Attachment B, pages 16-17 (September 27, 2007). Retrieved May 2013 at 

http://www.arb.ca.gov/planning/sip/2007sip/07-28_attachment_b.pdf

3

Per CAA §182(e)(5), the District is required to, in 2019, identify specific control measures that will achieve the 

emissions reductions necessary to fulfill the “black box” identified in Chapter 11, page 11-1. 

http://www.valleyair.org/Air_Quality_Plans/docs/AQ_Ozone_2007_Adopted/16%20Chapter%2011%20April%202007.pd

f 

4

 SJVUAPCD, 2012 PM2.5 Plan (December 20, 2012). Retrieved May 2013 at 

http://www.valleyair.org/Workshops/postings/2012/12-20-

12PM25/FinalVersion/09%20Chapter%209%20RACM%20RFP%20Contingency.pdf 
San Joaquin Valley Unified Air Pollution Control District January 31, 2014

Page 24 2013 Annual Demonstration Report 

 SIP Credit for Emission Reductions Generated Through Incentive Programs 

2008 PM2.5 Plan (Contingency Quantification, 2015): The District meets its 2008 

PM2.5 Plan commitment to quantify an adequate amount of contingency emissions 

reductions, including SIP-creditable emissions reductions from incentive programs 

quantified in this report (http://www.valleyair.org/Workshops/postings/2013/6-20-13-

R9601/PM25ContingencyQuantification.pdf). On August 28, 2013, EPA proposed to 

approve a SIP revision to address CAA nonattainment area contingency measure 

requirements for the 1997 annual and 24-hour fine particulate matter (PM2.5) NAAQS in 

the San Joaquin Valley.5 SIP Creditable incentive-based emission reductions accounted 

for by EPA in this proposed approval include on-road vehicle replacement projects that 

have been funded through the Prop 1B program and agricultural off-road vehicle 

replacement projects funded through the Carl Moyer Program. 

2007 Ozone Plan (Agricultural Equipment, 2017): The 2007 San Joaquin Valley 8-

Hour Ozone SIP, approved by EPA, contained a commitment by the ARB to present to 

their Board a regulation for off-road mobile agricultural equipment in 2013. The regulation 

would move California towards meeting ambient air quality standards for the Valley by 

utilizing the cleanest available technologies. Specifically, the approved SIP includes a 

goal to achieve emissions reductions of 5 to 10 tons per day of NOx from mobile 

agricultural equipment in the Valley by 2017 to accelerate progress toward attainment of 

the ozone standard. The attainment deadline is 2023. 

 

Beginning in 2009, the District and NRCS, in partnership with agricultural stakeholders, 

launched incentive programs aimed at reducing emissions from agricultural equipment. 

These programs have been well-funded and have achieved significant emission 

reductions since 2009. As documented in this report, projects implemented to date will 

achieve 6.68 tpd of NOx reductions in 2017 (see table 5), making significant progress, 

and in fact, already exceeding the minimum of 5tpd NOx commitment in the 2007 Ozone 

Plan. While included in this report, ARB plans on reporting on overall progress made 

relative to this SIP commitment in the 3rd quarter of 2013 (see below description of ARB’s 

ag equipment effort, and http://www.arb.ca.gov/ag/agtractor/agtractor.htm for further 

information). 

In addition to these already implemented projects, the District has already executed an 

additional $30.2 million in contracts for 737 units, projecting to achieve an additional 1.41 

tons of summertime NOx/day in 2017. NRCS has also executed an additional $36.5 

million in contracts for 688 units, projecting to achieve an additional 2.18 tons of 

summertime NOx/day. Combined with the reductions documented in this report, these 

projects are expected to achieve 10.27 tpd of NOx reductions in 2017. The District 

and NRCS are continuing to invest significant additional funding to replace agricultural 

equipment, and the total emissions reductions achieved towards this commitment is 

continued to grow substantially in the next several years. This progress will be 

documented in future annual demonstration reports. 

 

5

 EPA, Approval and Promulgation of Implementation Plans; California; San Joaquin Valley; Contingency Measures for 

the 1997 PM2.5 Standards, 78 Fed. Reg. 167, pp. 53113 – 53124. (2013, August 28). (to be codified at 40 CFR Part 

52). Retrieved November 2013 at http://www.gpo.gov/fdsys/pkg/FR-2013-08-28/pdf/2013-21010.pdf 
San Joaquin Valley Unified Air Pollution Control District January 31, 2014

Page 25 2013 Annual Demonstration Report 

 SIP Credit for Emission Reductions Generated Through Incentive Programs 

The agricultural equipment incentive-based emission reductions documented in this 

report have been summer-adjusted to allow for comparison with the 2007 Ozone Plan

commitment (based on summer ozone season), using the seasonal emissions inventory 

fractions included in the plan’s emissions inventory as follows: 

Table 4: 2007 Ozone Plan Agricultural Equipment Emissions Inventory Seasonal 

Fraction 

Season Seasonal Fraction 

Winter 0.391 

Summer 0.609 

ARB Rulemaking: ARB’s Regulation for State Implementation Plan Credit from Mobile 

Agricultural Equipment in the San Joaquin Valley was adopted by their Board in October 

2013. The regulation provides a mechanism to ensure that the agriculture industry’s 

voluntary participation in incentive programs in the San Joaquin Valley is recognized by 

the EPA. To meet EPA requirements, the emission reductions must be surplus, 

quantifiable, enforceable, and permanent. ARB’s regulation defines the criteria and 

process that ARB will use to determine that the reductions from the use of incentives 

generated from federal, state, and local funds spent on qualifying mobile agricultural 

equipment projects are surplus, quantifiable, enforceable, and permanent and are 

therefore eligible for SIP credit. 

2007 Ozone Plan (“Black Box” 2023): This commitment will be accounted for in future 

annual demonstration reports, since these reductions are necessary to be achieved in 

2023. 

2012 PM2.5 Plan (Contingency Quantification, 2020): This commitment will be 

accounted for in future annual demonstration reports, since these reductions are 

necessary to be achieved in 2020. 

B. Progress/Achievement of SIP Commitments 

The table below provides a summary of progress made towards meeting the above listed 

SIP commitments. 
San Joaquin Valley Unified Air Pollution Control District January 31, 2014

Page 26 2013 Annual Demonstration Report 

 SIP Credit for Emission Reductions Generated Through Incentive Programs 

Table 5: Summary of Progress Made Towards SIP commitments 

SIP Commitment Incentive Program 

Reductions 

(tpd) 

2008 PM2.5 Plan: 

4.15 tpd of NOx in 2015 

0.10 tpd of PM2.5 in 2015 

All data for NOx, 2015. See Section II for more information. 

Agricultural Off-road vehicle replacement 

projects funded through the Carl Moyer 

Program 

1.33 tpd NOx 

0.06 tpd PM2.5 

On-road vehicle replacement projects 

funded through the Prop 1B Program 

3.78 tpd NOx 

0.15 tpd PM2.5 

TOTAL (in 2015) 5.11 tpd NOx 

0.21 tpd PM2.5 

Commitment met? YES

2007 Ozone Plan: 

5-10 tpd of NOx from ag 

equipment in 2017 

All data for NOx, 2017. See Section II for more information.

District Ag Equipment Replacement 

Program (Moyer) 1.62* 

NRCS Combustion System Improvement 5.06* 

TOTAL 6.68* 

Percentage of commitment met to date 

(Remaining reductions to be demonstrated 

in future annual reports) 

133% 

2012 PM2.5 Plan: 

1.9 tpd of NOx in 2020 

To be demonstrated in future annual reports, since these 

reductions are for 2020 

2007 Ozone Plan Black Box

To be demonstrated in future annual reports (by 2019), since 

these reductions are for 2023 

*Adjusted for summer-time emissions inventory, 2007 Ozone Plan

C. SIP Commitment Shortfalls 

There are no shortfalls at this time; therefore, there are no remedy actions to be taken. 
San Joaquin Valley Unified Air Pollution Control District January 31, 2014

Page 27 2013 Annual Demonstration Report 

 SIP Credit for Emission Reductions Generated Through Incentive Programs 

V. MONITORING AND ENFORCEMENT ACTIVITIES 

Pursuant to Section 4.6 of Rule 9610 this annual demonstration report includes a 

summary of monitoring and enforcement activities that were conducted during the 

reporting period from 01/01/2009 – 05/13/2013. Monitoring is performed on all projects in 

the form of pre-inspections prior to contract, post-inspections prior to payment and annual 

usage surveys filled out by the grantee for the life of the project. 

Inspections are performed by District staff and include visually verify and photographically 

document equipment information such as but not limited to: 

· Make, model, and model year of the engine and/or vehicle or equipment, 

· Vehicle, equipment, and/or engine identification and serial numbers, 

· Operational condition of vehicle, equipment, and engine 

The District reviews all inspection information to ensure that the submitted information is 

true and accurate prior to contracting a new project and prior to payment of 

reimbursement requests from grantees. The table below illustrates the number of preinspection and post-inspection that were conducted during the reporting period. 

Table 6: Incentive Program Project Inspections 

Year Pre-Inspections Post-Inspections 

2009 1493 126 

2010 790 908 

2011 1138 973 

2012 2293 1355 

2013 1224 761 

District incentive project contractual agreements specify that Grantees must provide data 

to the District on an annual basis for the duration of their contract period. The required 

data includes usage data (mileage, hours of operation, percent utilization within the 

District, etc). The usage data is analyzed by the District to ensure that the incentive 

projects are achieving the projected emission reductions. The table below illustrates the 

quantity of usage report surveys distributed from the District to Grantees and the quantity 

of Grantee completed usage report surveys returned to the District through May 13, 2013. 

 
San Joaquin Valley Unified Air Pollution Control District January 31, 2014

Page 28 2013 Annual Demonstration Report 

 SIP Credit for Emission Reductions Generated Through Incentive Programs 

Table 7: Incentive Program Annual usage Reports 

Year 

Usage Report Surveys 

Distributed to 

Grantees 

Completed Usage Report

Surveys Returned to the 

District 

2011 1439 1126 

2012 3158 2786 

2013 389 281 

A. Carl Moyer Program Specific Monitoring and Enforcement Activities 

Project specific audits are conducted in addition to the monitoring and enforcement 

activities mentioned above. The project specific audits are conducted between November 

and December each calendar year and cover all Carl Moyer Program projects that have 

been implemented and are at least one year into their contracted project life but have not 

concluded their contracted project life. Projects selected for audit review consist of a 5% 

random sample of active projects or 30 projects (whichever is less) and all projects that 

are at least 6 months past due with their most recent annual usage survey. These audits 

follow procedures set forth in the 2008 Carl Moyer Program Guidelines. Projects selected 

for auditing are reviewed to ensure contract terms are fulfilled; emission reduction 

calculations are verified and project information is confirmed against the District database 

for accuracy. An inspection is conducted for each project to verify that the equipment, 

vehicle or practice is still owned (or in practice) by the Grantee and operational in the 

same piece of equipment and/or intended use as was contracted. Inspections also verify 

engine/equipment serial numbers, operational condition and verification of functioning 

odometer, hour meter/usage device, fuel receipts, or electronic monitoring unit. 

If deficiencies are discovered as part of an incentive project audit, the District utilizes 

several remedies, including: 

Deficiency: Underreporting usage on one or more annual 

report 

Potential Remedies: Extending project implementation phase 

Analyzing average usage over project 

implementation phase 

 Demanding return of funds from Grantee 

Deficiency: Non-submittal of annual reports 

Potential Remedies: Demanding return of funds from Grantee 

Excluding Grantee from future incentive 

programs 

Deficiency: Grantee no longer owns equipment 
San Joaquin Valley Unified Air Pollution Control District January 31, 2014

Page 29 2013 Annual Demonstration Report 

 SIP Credit for Emission Reductions Generated Through Incentive Programs 

Potential Remedies: Assign contract to new equipment owner 

Demanding return of funds from Grantee 

2010 Calendar Year Carl Moyer Project Specific Audit: This District conducted audit 

covered a project set of 408 projects which were at least 1 year into their project life. A 

5% random sample of these projects was selected totaling 20 projects consisting primarily 

of diesel Ag irrigation engines being replaced with electric motors. Of these projects, 5 

projects were found to be non-operational due to theft of copper wire, well failure, or 

closing of a business; 4 projects were found to have inaccurate reading, missing 

information or improper use of electric motor meters for recording hours of usage; and 2 

projects were found to have inaccurate annual usage survey information. In all cases 

except for the closure of a business, the observed deficiencies were fully resolved with no 

expected impact on emissions reductions. For the one project that had a closure of the 

business, the equipment was repossessed by creditors and the business entity was no 

longer viable thus leaving no recourse for the District. The project was closed and 

emissions reductions were not claimed. 

Of projects audited, 53% reported initial usages levels that were below contracted usage 

and 32% of the audited projects had past due annual usage surveys. Discrepancies 

between actual and contracted usage were generally due to the cyclical nature of 

agricultural irrigation needs. Projects with past due annual usage surveys were 

monitored and if the grantee failed to submit a survey within 6 months of the due date an 

inspector was sent out to take a meter reading. The reported usage did not affect the 

original incentive amounts or expected emissions reductions. Projects were not at the 

end of contracted project lives; therefore grantees could run the equipment additional 

hours and satisfy the terms on the agreement. 

2011 Calendar Year Carl Moyer Project Specific Audit: This District conducted audit 

covered a project set of 534 projects which were at least 1 year into their project life. A 

5% random sample of these projects was selected totaling 27 projects consisting primarily 

of diesel Ag irrigation engines being replaced with electric motors. Of these projects, 2 

projects were found to have had the associated property sold. In both cases, the District 

took no further action against the grantee. The projects were closed and the related 

emissions reductions were not claimed. 

Of projects audited, 54% reported initial usages levels that were below contracted usage 

on one or more of the engines in the project and 46% of the audited projects had past due 

annual usage surveys. Discrepancies between actual and contracted usage were 

generally due to the cyclical nature of agricultural irrigation needs. Projects with past due 

annual usage surveys were monitored and if the grantee failed to submit a survey within 6 

months of the due date an inspector was sent out to take a meter reading. The reported 

usage did not affect the original incentive amounts or expected emissions reductions of 

the projects. Those that did have a reduction in emissions due to reduced usage still had 

two (2) or more years remaining of their contracted project lives; therefore grantees could 

run the equipment additional hours and satisfy the terms on the agreement. 
San Joaquin Valley Unified Air Pollution Control District January 31, 2014

Page 30 2013 Annual Demonstration Report 

 SIP Credit for Emission Reductions Generated Through Incentive Programs 

One project had completed its implementation phase and had a reduction in emissions. In 

this case, it was determined that extending the contract term would allow the applicant to 

satisfy all contractual terms. The applicant signed a contract amendment extending the 

implementation phase. 

The following table shows projects that were determined to be in violation of their 

contractual terms and the enforcement actions that were taken by the District 

Table 8: Carl Moyer Program Projects with Contractual Violations 

Project Number Contractual Violation Action Taken 

No projects to report 

 

B. Proposition 1B Program Monitoring and Enforcement Activities 

In January 2007, Governor Schwarzenegger signed Executive Order S-02-07 which 

highlighted the importance of transparency and accountability in administering over $40 

billion in bond funding approved by California voters in 2006. The Executive Order directs 

all State government entities responsible for expending bond proceeds to establish and 

document a three part accountability structure. In 2008 Department of Finance (DOF) 

approved the accountability plan that ARB developed for the Proposition 1B Program 

which includes: 

· Front-end accountability, which defines the criteria for expending bond funds as 

well as the outcomes that the funds are intended to achieve. 

· In-progress accountability, which documents actions to ensure projects are staying 

within scope and cost, and requires semi-annual reports to the Department of 

Finance. 

· Follow up accountability, which requires Program review or fiscal audits to ensure 

expenditures achieved the intended outcomes and were consistent with legal 

requirements. 

The District evaluates Proposition 1B equipment projects on an ongoing basis though 

desk reviews of reports and equipment project updates provided by equipment owners, 

review of electronic monitoring unit data (as applicable), site inspections, equipment 

inspections, review of equipment maintenance and activity logs, and other measures 

deemed appropriate. In addition, equipment project contracts require that equipment 

owners permit the District, ARB, DOF, the Bureau of State Audits, or any authorize 

designees, access during normal business hours, to conduct ongoing evaluations for the 

purpose of monitoring the program. The following table shows projects that were 

determined to be in violation of their contractual terms and the enforcement actions that 

were taken by the District.
San Joaquin Valley Unified Air Pollution Control District January 31, 2014

Page 31 2013 Annual Demonstration Report 

 SIP Credit for Emission Reductions Generated Through Incentive Programs 

Table 9: Proposition 1B Program Projects with Contractual Violations 

Project Number Contractual Violation Action Taken 

No projects to report 

 

One applicant participating in this program was paid, per contract, $50,000 for the 

purchase of a replacement truck. The District found that the truck was not actually 

purchased by the applicant and District requested the applicant to refund the incentive 

funding or to fulfill contractual obligations by purchasing the replacement truck. The 

applicant responded that he/she no longer had funds, refused to return funding or 

purchase suitable replacement truck. The District filed a case in court against the 

applicant and received a judgment for $50,000 in October of 2012. 

C. Combustion Systems Improvement of Mobile Engines Program Monitoring and 

Enforcement Activities 

The USDA NRCS webpage at 

http://www.ca.nrcs.usda.gov/programs/eqip/eqip_program_eligibility.html summarizes 

program eligibility. The guidelines state the following: The Grantee has control of the land 

for the length of the proposed contract through deed, lease, or other written authorization. 

If the Grantee does not own the land, the landowner must give written consent to install, 

operate, and maintain the practice through the lifespan of the practice. Engine 

improvements are covered under Conservation Practice Standard 372 – Combustion 

System Improvement, posted on-line in the NRCS Field Office Technical Guide (FOTG) 

at: http://efotg.sc.egov.usda.gov/references/public/CA/372-std-09-2010.pdf. The CPS 

372 practice life is 10 years as described on the FOTG spreadsheet at: 

http://efotg.sc.egov.usda.gov/references/public/CA/List_of_Practices_Lifespans_2012-

12_CA_Numeric.xlsx. NRCS incentive program contracts state that if the tractor is not 

retained for 10-years then the Grantee will owe a pro-rated amount back to the NRCS. 

With regards to the identification of project audits, usage reports, inspections, and other 

project monitoring activities including enforcement actions as required to Section 4.6 of 

Rule 9610, the Combustion Systems Improvement of Mobile Engines incentive program 

is unique from other incentive programs in that NRCS is explicitly prohibited from 

identifying grantees by name. As directed by the Farm Bill (Food Security Act of 1985 (7 

U.S.C. § 608d(2))), NRCS must maintain the confidentiality of information provided by an 

agricultural producer participating in the NRCS Combustion Systems Improvement of 

Mobile Engines incentive program. The information is exempt from mandatory disclosure 

and may not be used in judicial or administrative proceedings without the consent of the 

person involved. That said, the USDA NRCS is currently reviewing their processes and 

may in future years be able to provide additional information for purposes of the District’s 

annual demonstration reports. 
San Joaquin Valley Unified Air Pollution Control District January 31, 2014

Page 32 2013 Annual Demonstration Report 

 SIP Credit for Emission Reductions Generated Through Incentive Programs 

VI. INCENTIVE PROGRAM EVALUATION 

The District’s incentive programs have been developed around several core principles, 

including cost-effectiveness, integrity, effective program administration, excellent 

customer service, the efficient use of District resources, fiscal transparency and public 

accountability. As a result of these focused efforts, the District has become a statewide 

leader in incentive programs with several elements of these programs being held as 

models for other air districts’ incentive programs throughout California. In fact, the ARB 

routinely calls upon the District to administer statewide incentive programs on their behalf 

and on behalf of other local air districts. Recent examples include administering the 

Lower Emission School Bus Program on behalf of ARB and 18 other air districts, the 

statewide Agricultural Utility Terrain Vehicle (UTV) program and the statewide School Bus 

Retrofit Program. 

The District is regularly audited by independent outside agencies including professional 

accountancy corporations on behalf of the federal government, ARB, the California DOF 

and the California Bureau of State Audits. These comprehensive and rigorous 

independent audits focus on every aspect of our incentive programs including District 

programmatic and fiscal controls. These audits are conducted to ensure that the public 

funds to which the District has been entrusted are spent appropriately and in the manner 

in which they were intended. The District welcomes these opportunities to gain valuable 

feedback regarding implementation of these critical programs. Periodic evaluations such 

as these are important tools that the District uses to ensure continuous improvement in 

operation of these core emission reduction strategies. Towards that end, the District’s 

incentive programs were recently audited by ARB and DOF, including a thorough review 

of several of the District’s largest and most complex incentive programs totaling more 

than $215 million over a four year period. The audits focused on the District’s 

implementation of the following programs: 

· Carl Moyer Memorial Air Quality Standards Attainment Program, 

· Air Quality Improvement Program, 

· Proposition 1B: Goods Movement Emission Reduction Program, 

· Proposition 1B: Lower Emission School Bus Program, and 

· Federal Diesel Emission Reductions Act School Bus Program 

These audits included an extensive desk review of specific projects, a thorough review of 

District internal programmatic and fiscal policies and procedures, and field validation of 

projects to ensure that the expected emission reductions were being achieved in practice. 

Overall, the results of the audits confirmed that the District’s incentive programs are 

fiscally sound and are “efficiently and effectively achieving their emission reduction 

objectives.” ARB’s audit report concluded that the District is meeting or exceeding all 

requirements for the expenditure of funds and commended the District for administering 

the Proposition 1B Lower Emission School Bus Program on behalf of 18 other local air 

districts. However, the District is continually identifying opportunities to refine its incentive 

programs and improve the operational efficiency and effectiveness. 
San Joaquin Valley Unified Air Pollution Control District January 31, 2014

Page 33 2013 Annual Demonstration Report 

 SIP Credit for Emission Reductions Generated Through Incentive Programs 

The most recent audits of District administered incentive programs can be found online at 

http://www.arb.ca.gov/msprog/moyer/audits/2011/san_joaquin_valley.htm 

This section intentionally blank. 

 
San Joaquin Valley Unified Air Pollution Control District January 31, 2014

Page 34 2013 Annual Demonstration Report 

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San Joaquin Valley Unified Air Pollution Control District June 20, 2013

Page 35 2013 Annual Demonstration Report 

 SIP Credit for Emission Reductions Generated Through Incentive Programs 

VII. SUMMARY OF EMISSION REDUCTIONS AND COST EFFECTIVENESS 

The SIP-creditable incentive-based emission reductions represented in this 2013 Annual Demonstration Report are from 

incentive projects implemented 1/1/2009 through 5/13/2013. The data represented in these tables will continue to be 

updated through each annual demonstration report as more projects are implemented each year. Although the purpose of 

District Rule 9610 is to claim SIP credit for incentive-based emission reductions in the Valley through incentive programs 

administered by the District, NRCS, or ARB, this 2013 Annual Demonstration Report only claims SIP credit for those 

programs administered by the District and NRCS. Future annual demonstration reports may include programs administered 

by ARB. For the detailed data used to create the following summary tables, refer to the 2013 Annual Demonstration Report 

Data Sheet, available electronically with this annual demonstration report. 

Program Summaries 

The following table summarizes the total SIP-creditable incentive-based emission reductions generated through incentive 

programs, expressed in tons per year and tons per day, claimed in this 2013 Annual Demonstration Report. This summary 

includes SIP-creditable incentive-based emission reductions claimed through incentive program guidelines identified in 

Sections 3.1 and 3.2 of Rule 9610. 

Table 10: Total SIP-Creditable Incentive-Based Emission Reductions Generated Through Incentive Programs 

Pollutant 

Emissions Reduced (tons per year) 

2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 

NOx 1103.44 2660.32 4173.72 5680.67 5725.43 4726.75 4015.30 3432.89 2561.94 2472.73 2079.01 1366.10 

PM 36.29 83.56 144.88 206.30 208.10 177.60 162.59 139.15 105.92 102.48 89.06 60.66 

ROG 116.23 236.79 366.02 452.52 453.88 381.83 370.03 364.03 358.05 351.10 283.63 187.79 

Emissions Reduced (tons per day) 

2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 

NOx 3.02 7.29 11.43 15.56 15.69 12.95 11.00 9.41 7.02 6.77 5.70 3.74

PM 0.10 0.23 0.40 0.57 0.57 0.49 0.45 0.38 0.29 0.28 0.24 0.17

ROG 0.32 0.65 1.00 1.24 1.24 1.05 1.01 1.00 0.98 0.96 0.78 0.51
San Joaquin Valley Unified Air Pollution Control District June 20, 2013

Page 36 2013 Annual Demonstration Report 

 SIP Credit for Emission Reductions Generated Through Incentive Programs 

Tables 11 and 12 below are the subsets of the summary provided in Table 10. Table 9 identifies emission reductions 

claimed through incentive program guidelines pursuant to Section 3.1 of Rule 9610. Table 10 identifies emission reductions 

claimed through incentive program guidelines pursuant to Section 3.2 of Rule 9610. 

Table 11: Emission Reductions Claimed through use of Incentive Program Guidelines Pursuant to Section 3.1 

Pollutant Emissions Reduced (tons per year) 

2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 

NOx 1086.37 2643.25 4151.00 5597.52 5642.28 4643.61 3932.15 3349.74 2478.79 2389.58 1996.21 1283.30 

PM 35.72 82.98 143.96 202.37 204.18 173.68 158.67 135.22 101.99 98.56 85.16 56.75 

ROG 114.60 235.17 364.05 444.22 445.58 373.53 361.73 355.73 349.75 342.80 275.36 179.52 

 

Emissions Reduced (tons per day) 

2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 

NOx 2.98 7.24 11.37 15.34 15.46 12.72 10.77 9.18 6.79 6.55 5.47 3.52 

PM 0.10 0.23 0.39 0.55 0.56 0.48 0.43 0.37 0.28 0.27 0.23 0.16 

ROG 0.31 0.64 1.00 1.22 1.22 1.02 0.99 0.97 0.96 0.94 0.75 0.49 

Table 12: Emission Reductions Claimed through use of Incentive Program Guidelines Pursuant to Section 3.2 

Pollutant

Emissions Reduced (tons per year)

2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 

NOx 17.06 17.06 22.72 83.15 83.15 83.15 83.15 83.15 83.15 83.15 82.80 82.80 

PM 0.58 0.58 0.92 3.92 3.92 3.92 3.92 3.92 3.92 3.92 3.91 3.91 

ROG 1.62 1.62 1.97 8.30 8.30 8.30 8.30 8.30 8.30 8.30 8.28 8.28 

 

Emissions Reduced (tons per day) 

2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 

NOx 0.05 0.05 0.06 0.23 0.23 0.23 0.23 0.23 0.23 0.23 0.23 0.23 

PM 0.00 0.00 0.00 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 

ROG 0.00 0.00 0.01 0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.02 
San Joaquin Valley Unified Air Pollution Control District June 20, 2013

Page 37 2013 Annual Demonstration Report 

 SIP Credit for Emission Reductions Generated Through Incentive Programs 

Cost Effectiveness 

The table below is a summary of the overall cost effectiveness (expressed as dollars per ton of emissions reduced), 

including incentive contributions, and total lifetime emission reductions, for District-administered incentive programs claimed 

in this annual demonstration report that utilized the Carl Moyer and Proposition 1B incentive program guidelines as 

identified in Sections 3.1 and 3.2 of Rule 9610. Because each incentive program guideline calculates cost effectiveness 

differently, the cost-effectiveness represented in Table 13 was calculated by first determining the cost effectiveness for 

each individual project and then averaging that number for all projects accounted for. 

Table 13: Summary of District-Administered Incentive Programs 

Project Type 

Incentive 

Contribution 

Provided 

Grantee 

Investment 

Total Emissions 

Reductions 

(Lifetime tons) 

Cost 

Effectiveness 

($/tons) 

Off-Road Mobile Equipment 

Replacement/Repower/Retrofit 1

$35,774,661.59 $28,819,236.24 7,557.19 $4,881.28 

Agricultural Pump Repower1

$25,945,807 $8,035,811 8086.21 $5,185.30 

New Electric Agricultural Pump1

$335,144 $1,463,625 387.81 $1,466.23 

Trucks Replacement1

$89,409,800 $118,119,558 10593.76 $14,051.12 

Locomotives Repower2

$16,919,908 $4,509,370 1805.24 $8,940.96 

New Off-Road Mobile Equipment2,3 $82,822 $193,296 3.94 $20,916.97 

1. SIP-creditable incentive-based emission reductions claimed through incentive program guidelines identified in Section 3.1 of Rule 9610. 

2. SIP-creditable incentive-based emission reductions claimed through incentive program guidelines identified in Section 3.2 of Rule 9610. 

3. New Off-Road Mobile Equipment is specific to the new purchase of electric large spark ignition (LSI) forklifts. 

Carl Moyer Incentive Program Guidelines 

The following set of tables summarize the amount of emission reductions claimed in the SIP under Rule 9610 for incentive 

programs administered by the District using the Carl Moyer Incentive Program Guidelines. Table 14 summarizes the total 

SIP-creditable incentive-based emission reductions claimed under Sections 3.1 and 3.2 of Rule 9610. Tables 13 through 

16 summarize the emission reductions claimed in the SIP from incentive program guidelines identified in Section 3.1 of Rule 

9610, while Table 19 summarizes emission reductions claimed in the SIP for locomotive alternative technology switchers 

projects and new electric forklift purchases, pursuant to Section 3.2 of the rule. 
San Joaquin Valley Unified Air Pollution Control District June 20, 2013

Page 38 2013 Annual Demonstration Report 

 SIP Credit for Emission Reductions Generated Through Incentive Programs 

Table 14: Total Claimed SIP-Creditable Incentive-Based Emission Reductions Using the Carl Moyer Guidelines 

Pollutant 

Emissions Reduced (tons per year) 

2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 

NOx 865.21 1179.70 1568.04 2105.04 2111.29 1203.82 1064.54 1003.99 951.86 901.84 654.55 607.64 

PM 22.52 31.19 46.24 69.27 69.84 47.87 45.07 43.46 40.90 38.64 30.65 28.43 

ROG 96.41 124.29 170.21 236.49 237.84 165.80 154.00 148.00 142.02 135.07 87.41 84.26 

 

Emissions Reduced (tons per day) 

2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 

NOx 2.37 3.23 4.30 5.77 5.78 3.30 2.92 2.75 2.61 2.47 1.79 1.66 

PM 0.06 0.09 0.13 0.19 0.19 0.13 0.12 0.12 0.11 0.11 0.08 0.08 

ROG 0.26 0.34 0.47 0.65 0.65 0.45 0.42 0.41 0.39 0.37 0.24 0.23 

Table 15: SIP-Creditable Incentive-Based Emission Reductions for Off-Road Compression-Ignition Equipment 

Replacement Claimed Pursuant to Section 3.1 

Pollutant Emissions Reduced (tons per year) 

2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 

NOx 0.00 0.00 170.33 469.96 484.47 484.47 484.47 484.47 484.47 484.47 484.47 484.47 

PM 0.00 0.00 7.73 22.81 23.44 23.44 23.44 23.44 23.44 23.44 23.44 23.44 

ROG 0.00 0.00 25.47 72.08 73.83 73.83 73.83 73.83 73.83 73.83 73.83 73.83 

 

Emissions Reduced (tons per day) 

2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 

NOx 0.00 0.00 0.47 1.29 1.33 1.33 1.33 1.33 1.33 1.33 1.33 1.33 

PM 0.00 0.00 0.02 0.06 0.06 0.06 0.06 0.06 0.06 0.06 0.06 0.06 

ROG 0.00 0.00 0.07 0.20 0.20 0.20 0.20 0.20 0.20 0.20 0.20 0.20 
San Joaquin Valley Unified Air Pollution Control District June 20, 2013

Page 39 2013 Annual Demonstration Report 

 SIP Credit for Emission Reductions Generated Through Incentive Programs 

Table 16: SIP-Creditable Incentive-Based Emission Reductions for Off-Road Compression-Ignition Equipment 

Repower and Retrofit Claimed Pursuant to Section 3.1 

Pollutant

Emissions Reduced (tons per year) 

2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 

NOx 57.54 108.86 158.88 209.04 213.21 205.70 202.80 152.77 105.18 55.17 5.43 0.42 

PM 1.57 4.12 6.38 8.05 8.24 7.94 7.77 6.50 4.18 1.92 0.25 0.00 

ROG 6.30 12.41 19.36 25.51 26.08 25.24 24.85 19.39 13.73 6.78 0.63 0.00 

 

Emissions Reduced (tons per day) 

2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 

NOx 0.16 0.30 0.44 0.57 0.58 0.56 0.56 0.42 0.29 0.15 0.01 0.00 

PM 0.00 0.01 0.02 0.02 0.02 0.02 0.02 0.02 0.01 0.01 0.00 0.00 

ROG 0.02 0.03 0.05 0.07 0.07 0.07 0.07 0.05 0.04 0.02 0.00 0.00 

Table 17: SIP-Creditable Incentive-Based Emission Reductions for Repower of Agricultural Pumps Engines 

Claimed Pursuant to Section 3.1 

Pollutant Emissions Reduced (tons per year) 

2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 

NOx 790.60 1036.20 1190.57 1307.02 1294.60 394.63 258.26 247.75 243.19 243.19 46.00 21.66 

PM 20.38 25.64 30.22 33.45 33.21 11.53 8.90 8.56 8.32 8.32 2.02 0.89 

ROG 88.49 109.36 122.05 128.72 127.75 56.54 45.13 44.59 44.27 44.27 2.79 1.18 

 

Emissions Reduced (tons per day) 

2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 

NOx 2.17 2.84 3.26 3.58 3.55 1.08 0.71 0.68 0.67 0.67 0.13 0.06 

PM 0.06 0.07 0.08 0.09 0.09 0.03 0.02 0.02 0.02 0.02 0.01 0.00 

ROG 0.24 0.30 0.33 0.35 0.35 0.15 0.12 0.12 0.12 0.12 0.01 0.00 
San Joaquin Valley Unified Air Pollution Control District June 20, 2013

Page 40 2013 Annual Demonstration Report 

 SIP Credit for Emission Reductions Generated Through Incentive Programs 

Table 18: SIP-Creditable Incentive-Based Emission Reductions for Purchase of New Electric Agricultural Pump 

Motors Claimed Pursuant to Section 3.1 

Pollutant

Emissions Reduced (tons per year) 

2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 

NOx 0.00 17.57 25.54 35.86 35.86 35.86 35.86 35.86 35.86 35.86 35.86 18.29 

PM 0.00 0.85 0.99 1.04 1.04 1.04 1.04 1.04 1.04 1.04 1.04 0.19 

ROG 0.00 0.91 1.37 1.88 1.88 1.88 1.88 1.88 1.88 1.88 1.88 0.98 

 

Emissions Reduced (tons per day) 

2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 

NOx 0.00 0.05 0.07 0.10 0.10 0.10 0.10 0.10 0.10 0.10 0.10 0.05 

PM 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

ROG 0.00 0.00 0.00 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.00 

Table 19: SIP-Creditable Incentive-Based Emission Reductions for Locomotives and New Electric Forklift 

Purchase Claimed Pursuant to Section 3.2 

Pollutant Emissions Reduced (tons per year) 

2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 

NOx 17.06 17.06 22.72 83.15 83.15 83.15 83.15 83.15 83.15 83.15 82.80 82.80 

PM 0.58 0.58 0.92 3.92 3.92 3.92 3.92 3.92 3.92 3.92 3.91 3.91 

ROG 1.62 1.62 1.97 8.30 8.30 8.30 8.30 8.30 8.30 8.30 8.28 8.28 

 

Emissions Reduced (tons per day) 

2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 

NOx 0.05 0.05 0.06 0.23 0.23 0.23 0.23 0.23 0.23 0.23 0.23 0.23 

PM 0.00 0.00 0.00 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 

ROG 0.00 0.00 0.01 0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.02 
San Joaquin Valley Unified Air Pollution Control District June 20, 2013

Page 41 2013 Annual Demonstration Report 

 SIP Credit for Emission Reductions Generated Through Incentive Programs 

Proposition 1B Incentive Program Guidelines 

The following table is a summary of incentive-based emission reductions claimed in the SIP from incentive programs 

administered by the District using the Proposition 1B incentive program guidelines, as identified in Section 3.1 of Rule 9610. 

Table 20: SIP-Creditable Incentive-Based Emission Reductions for On-Road Trucks 

Pollutant Emissions Reduced (tons per year) 

2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 

NOx 91.80 668.19 1185.92 2004.74 2043.25 1952.05 1379.87 858.01 39.20 0.00 0.00 0.00 

PM 8.35 20.76 41.43 73.18 74.41 65.89 53.68 31.85 1.18 0.00 0.00 0.00 

ROG 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

 

Emissions Reduced (tons per day) 

2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 

NOx 0.25 1.83 3.25 5.49 5.60 5.35 3.78 2.35 0.11 0.00 0.00 0.00 

PM 0.02 0.06 0.11 0.20 0.20 0.18 0.15 0.09 0.00 0.00 0.00 0.00 

ROG 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 
San Joaquin Valley Unified Air Pollution Control District June 20, 2013

Page 42 2013 Annual Demonstration Report 

 SIP Credit for Emission Reductions Generated Through Incentive Programs 

NRCS Combustion Systems Improvement of Mobile Equipment Incentive Program Guidelines 

The following table provides a summary of the SIP-creditable incentive-based emission reductions claimed in the SIP for 

incentive projects administered by the NRCS, as identified in Section 3.1 of Rule 9610. 

Table 21: SIP-Creditable Incentive-Based Emission Reductions for Agricultural Equipment 

Pollutant Emissions Reduced (tons per year) 

2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 

NOx 145.08 789.92 1353.02 1495.72 1495.72 1495.72 1495.72 1495.72 1495.72 1495.72 1350.65 705.80

PM 5.35 30.37 54.30 60.64 60.64 60.64 60.64 60.64 60.64 60.64 55.29 30.27 

ROG 19.37 108.54 188.64 207.87 207.87 207.87 207.87 207.87 207.87 207.87 188.50 99.33 

 

Emissions Reduced (tons per day) 

2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 

NOx 0.40 2.16 3.71 4.10 4.10 4.10 4.10 4.10 4.10 4.10 3.70 1.93 

PM 0.01 0.08 0.15 0.17 0.17 0.17 0.17 0.17 0.17 0.17 0.15 0.08 

ROG 0.05 0.30 0.52 0.57 0.57 0.57 0.57 0.57 0.57 0.57 0.52 0.27 

Case-By-Case Determinations

The following table provides a summary of the SIP-creditable incentive-based emission reductions for incentive projects that 

have been approved through a case-by-case process as identified in section 3.2.2 of Rule 9610. 

Table 22: Summary of Case-By-Case Determinations 

Project Number 

Total Emissions Reductions 

(Lifetime tons) 

Cost Effectiveness 

($/ton) 

No projects to report 

 

 
San Joaquin Valley Unified Air Pollution Control District June 20, 2013

Page A-1 2013 Annual Demonstration Report 

 SIP Credit for Emission Reductions Generated Through Incentive Programs 

Appendix A 

District Incentive Program Project Information 

 
San Joaquin Valley Unified Air Pollution Control District June 20, 2013

Page A-2 2013 Annual Demonstration Report 

 SIP Credit for Emission Reductions Generated Through Incentive Programs 

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San Joaquin Valley Unified Air Pollution Control District June 20, 2013

Page B-1 2013 Annual Demonstration Report 

 SIP Credit for Emission Reductions Generated Through Incentive Programs 

Appendix B 

NRCS Combustion System Improvement Program Project Information 

 
San Joaquin Valley Unified Air Pollution Control District June 20, 2013

Page B-2 2013 Annual Demonstration Report 

 SIP Credit for Emission Reductions Generated Through Incentive Programs 

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