GOVERNING BOARD

Hub Walsh, Chair Supervisor, Merced County

Tom Wheeler, Vice Chair Supervisor, Madera County

Oliver L. Baines III Councilmember, City of Fresno

Tony Barba Supervisor, Kings County

Skip Barwick Councilmember, City of Tulare

Sally J. Bomprezzi Councilmember, City of Madera

Dennis Brazil Mayor, City of

John Capitman, Ph.D. Appointed by Governor

Judith G. Case McNairy Supervisor, Fresno County

David Couch Supervisor, Kern County

Bob Elliott Supervisor, San Joaquin County

Harold Hanson Councilmember, City of Bakersfield

William O’Brien Supervisor, Stanislaus County

Alexander C. Sherriffs, M.D. Appointed by Governor

J. Steven Worthley Supervisor, Tulare County

Seyed Sadredin

Executive Director
Air Pollution Control Officer

Northern Region Office 4800 Enterprise Way Modesto, CA 95356

- 8718 (209) 557

- 6400 • FAX (209) 557

- 6475

Central Region Office 1990 East Gettysburg Avenue Fresno, CA 93726

- 0244 (559) 230

- 6000 • FAX (559) 230

- 6061

Southern Region Office 34946 Flyover Court Bakersfield, CA 93308

- 9725 (661) 392

- 5500 • FAX (661) 392

- 5585

www.valleyair.org DATE: September 18, 2014

TO: SJV UAP CD G overning B oard

FROM: Seyed Sadredin, Executive Director/APCO

Project Coordinator: Sheraz Gill

RE: ITEM NUMBER 6 : REVIEW AND APPROVE SIP

ACTIONS IN RELATION TO THE 2006 PM2.5

STANDARD TO ADDRESS AIR QUALITY IMPACTS

RESULTING FROM THE EXCEPTIONAL

WEATHER CONDITIONS CAUSED BY THE

RECENT DROUGHT

RECOMMENDATION S :

1. D irect the Executive Director/APCO to submit the attached Supplemental Document to the U.S. Environmental Protection Agency (EPA) demonstrating that the 2012 PM2.5 Plan meets applicable requirements under Clean Air Act (CAA) subpart 4

.

2. Direct the Executive Director/APCO to submit a formal request to the U.S. Environmental Protection Agency (EPA) to reclassify the San Joaquin Valley as a Serious nonattainment area for the

federal 2006 PM2.5 standard.

3. Direct the Executive Director/APCO to explore the feasibility and potential means for integrating planning mandates for the three pending particulate matter standards (1997, 2006, and 2012 PM2.5 standards), and to work to garner ARB and EPA’s support for a streamlined approach that avoids unnecessary duplication.

BACKGROUND :

The District’s 2012 PM2.5 Plan satisfied all federal implementation requirements for the 2006 PM2.5 standard at the time of adoption by your Board on December 20, 2012. Two weeks later, on January 4,
2013, t he D.C. Circuit Court ruled that EPA erred by us ing Clean Air

Act (CAA) subpart 1 instead of subpart 4 in establishing its PM2.5SJV

U APCD Governing Board

I TEM NUMBER 6: REVIEW AND APPROVE SIP ACTIONS IN RELATION TO THE 2006 PM2.5

STANDARD TO ADDRESS AIR QUALITY IMPACTS RESULTING FROM THE EXCEPTIONAL

WEATHER CONDITIONS CAUSED BY THE RECENT DROUGHT September 18, 2014

2 implementation rule, upon which the District’s and other PM2.5 plans nationwide had

been based.

On June 2, 2014, EPA classified all PM2.5 areas as “Moderate” under subpart 4, setting

an attainment deadline of 2015 for the 2006 PM2.5 standard. Due to the extreme drought and related meteorological conditions experienced in 2013

- 2014, the Valley’s PM2.5 values were significantly impacted and this deadline cannot be met. The

D istrict’s Supplemental Document demonstrat es how the 2012 PM2.5 Plan meets applicable requirements under CAA subpart 4 and requests that the Valley be

reclassified to “Serious” nonattainment for the 2006 PM2.5 standard. This sets the stage for adopting a plan within 18 months of formal EPA action to reclassify the Valley

as Serious for the 2006 standard. This plan will be in addition to plans under way for

the 1997 and 2012 PM2.5 standards.

DISCUSSION :

At the August 21, 2014 hearing, your Board heard an item regarding the extraordinary drought conditions in the winter 2013

- 2014, which resulted in abnormally high PM2.5

concentrations and which have made attainment of the 1997 PM2.5 standard by the

current 2014 deadline impossible. These conditions are not considered “exceptional

event s” under EPA’s current policy for excluding uncontrollable events from attainment determinations. The District is pursuing legislative and administrative remedies for a

more common sense definition of “exceptional events,” but this process is expected to take some time. The Governing Board authorized the APCO to request reclassification

from “Moderate” to “Serious” for the 1997 PM2.5 standard immediately, and to prepare

a ne w attainment plan meeting “Serious” area requirements in spring of 2015. This new plan will establish a new attainment date with up to an additional 5 years to reach attainment (up to 2020), as allowed by CAA Subpart 4.

Subpart 4 and the exceptional drou ght are also impacting the Valley under EPA’s 2006
PM2.5 standard, which was set at 3 5 μ g/m 3 as averaged over a 24

- hour period. Although the District’s 2012 PM2.5 Plan for the 2006 standard was adopted before the 2013 court decision requiring PM2.5 implementation under subpart 4, EPA must now evaluate all PM2.5 plans under that subpart.

The District’s Supplemental Document demonstrates that the District meets all sub part 4 requirements:

1. The “Moderate” attainment date of 2015 is impracticable

On June 2, 2014, EPA classified all PM2.5 nonattainment areas as “Moderate”
under both the 1997 and 2006 standards. For the 2006 standard, this sets the Valley’s initial attain ment date at 2015.SJV

U APCD Governing Board

ITEM NUMBER 6: REVIEW AND APPROVE SIP ACTIONS IN RELATION TO THE 2006 PM2.5

STANDARD TO ADDRESS AIR QUALITY IMPACTS RESULTING FROM THE EXCEPTIONAL

WEATHER CONDITIONS CAUSED BY THE RECENT DROUGHT September 18, 2014

3 Over the winter of 2013

- 14, the Valley and many other areas in California shattered previous records for low levels of precipitation (Table 1) , and are currently considered experiencing an “Exceptional Drought” by the federal U.S. Dep artment of Agriculture (Figure 1)

. The Valley’s atmospheric stability was also the strongest experienced over the 15

- year history of PM2.5 monitoring (Figure 2 ). These conditions were very conducive to formation and retention of PM2.5, and very high

PM2. 5 concentrations were recorded throughout the Valley as a result. Attainment

of the 2006 24

- hour PM2.5 standard is based on a three

- year average of 98 th

percentile values, which are amongst the highest values recorded over the course of the calendar year. Although the 98 th percentile values were on the decline in 2012, 2013 values are so high that attainment in 2015 (based on 2013

- 20 15 data) is impossible. As illustrated in Table 2, with conservative assumptions for

concentrations in 2014 , it is impossibl e for many sites in the Valley to attain in 2015.

Table 1: Calendar Year Rainfall Totals for Select California Cities

City 1981

- 2010

Average (inches) 2013 Total (inches) Previous Record

Low (inches) Previous

Record Year

Modesto 13.11 4.70 5.70 1929

Merced 12.50 3.79 6.00 2007

Fresno 11.50 3.01 3.55 1947

Visalia 10.93 3.47 4.10 1910

Bakersfield 6.47 3.43 1.87 1959

Sacramento 18.52 5.81 6.67 1976

San Francisco 23.65 5.59 9.00 1917

San Jose 14.90 3.80 6.04 1929 Los Angeles 12.82 3.65 4.08 1953 San Diego 10.34 5.57 3.41 1953SJV

U APCD Governing Board

ITEM NUMBER 6: REVIEW AND APPROVE SIP ACTIONS IN RELATION TO THE 2006 PM2.5

STANDARD TO ADDRESS AIR QUALITY IMPACTS RESULTING FROM THE EXCEPTIONAL

WEATHER CONDITIONS CAUSED BY THE RECENT DROUGHT September 18, 2014

4

Figure 1: Valley Experiencing “Exceptional Drought”

Figure 2 : Average Atmospheric Stability per Winter Season

-1.5 -1 -0.5 0 0.5 1 1.5 2 2.5 3 3.5

1999-2000 2000-2001 2001-2002 2002-2003 2003-2004 2004-2005 2005-2006 2006-2007 2007-2008 2008-2009 2009-2010 2010-2011 2011-2012 2012-2013 2013-2014 T850MB Stability Parameter ( ̊C)SJV

U APCD Governing Board

ITE M NUMBER 6: REVIEW AND APPROVE SIP ACTIONS IN RELATION TO THE 2006 PM2.5

STANDARD TO ADDRESS AIR QUALITY IMPACTS RESULTING FROM THE EXCEPTIONAL

WEATHER CONDITIONS CAUSED BY THE RECENT DROUGHT September 18, 2014

5 Table 2: 98 th Percentile PM2.5 Comparison , Showing 2015 Attainment (Based on

2013

- 2015 Data) is Impossible

Site 98 th Percentile Values

Measured Values Hypothetical Values

2012

P rogress
towards

attainment 2013

Exceptional weather impacts 2014

Projected,

based on

e xceptional

weather impacts* 2015

Max. allowed

for attainment

Stockton

- Hazelton 33.9 56.3 48.0 1.9

Manteca 30.9 40.2 40.0 26.0

Modesto 40.8 56.4 53.0

- 3.2

Turlock 45.4 55.4 51.0

- 0.2

Merced

- M 37.2 57.2 53.7

- 4.7

Merced

- Coffee 35.6 42.3 40.0 23.9

Madera

- City 43.2 54.6 51.0 0.6

Clovis 48.0 56.2 57.0

- 7.0

Fresno

- Garland 52.6 63.8 66.0

- 23.6

Fresno

- Pacific 42.8 59.1 74.5

- 27.4
Tranquility 26.9 35.7 28.0 42.5

Corcoran 40.0 56.1 75.9

- 25.8

Hanford 48.3 67.6 78.0

- 39.4

Visalia

- Church 53.8 62.5 67.0

- 23.3

Bakersfield

- California 56.4 71.8 72.0

- 37.6

Bakersfield

- Planz 40.6 96.7 76.7

- 67.2 * Conservative, based on partial

- year data.

In addition, the 2012 PM2.5 Plan included emissions inventory analysis showing that attainment by 2015 is impractical

. For example, a n additional 11.8 tons per day of NOx reductions would be needed in Kern County in 2015

– equivalent to eliminating all passenger vehicles and 75% of stationary sources in that county.

So in terms of both measured PM2.5 concentrations in 2013 and emission s inventory trends, attainment of the 2006 PM2.5 standard by 2015 is not possible. As such, the Valley should be reclassified as “Serious” for the 2006 PM2.5 standard, with an attainment deadline of up to 2019, consistent with the 2012

PM2.5 Plan

.

As no ted in the 2012 PM2.5 Plan

, the implementation of several key control

measures is needed for the Valley to secure the emissions reductions necessary

to attain the 2006 PM2.5 standard , including :SJV

U APCD Governing Board

ITEM NUMBER 6: REVIEW AND APPROVE SIP ACTIONS IN RELATION TO THE 2006 PM2.5

STANDARD TO A DDRESS AIR QUALITY IMPACTS RESULTING FROM THE EXCEPTIONAL

WEATHER CONDITIONS CAUSED BY THE RECENT DROUGHT September 18, 2014

6

 Continued implementation of the over 500 rules and rule amend ments adopted by the District

 Amendments to Rule 4901 (Wood Burning Fireplaces and Wood Burning Heaters)

 Upcoming amendments to Rule 4692 (Commercial Charbroiling), expected in 2016

 ARB mobile source regulations and associated fleet turnover

2. Reasonably Available Control Measures (RACM)

The 2012 PM2.5 Plan addressed RACM for PM2.5, NOx, and SOx. However, under subpart 4 areas must also address other potential precursors of PM2.5, including ammonia and VOCs, unless it is shown that they do not contribute to attainment.

The 2012 P lan already included extensive scientific analysis demonstrating that

ammonia and VOC reductions do not contribute to attainment. For example, i t would take a total ammonia reduction of 125 tons per day

– 34% o f the Valley’s total emissions inventory

– for the Valley to achieve only a 1 μg/m3 reduction in the PM2.5 design value.

Nationwide, as regions continue to look into the issue of ammonia as a PM2.5 precursor, research should continue to assess the relat ionship between ammonia emissions and ambient PM2.5 emissions. Ammonia control measures should only be required if additional ammonia reductions are found to be needed to meet health

based air quality standards.

While ammonia has been demonstrated to not significantly contribute to PM2.5 concentrations in the Valley , the Supplemental Document demonstrates the significant reductions in ammonia achieved through the Valley’s stringent regulations, including:

 Confined Animal Facilities (District Rule 4570)

 Organic Material Composting (District Rule 4566)

 Biosolids, Animal Manure, and Poultry Litter Operations (District Rule 4565)

 State regulations related to agricultural fertilizer application

Based on the District’s analysis , there are no additional ammoni a controls the District could adopt that would advance PM2.5 attainment. Because the science indicates that ammonia reductions do not contribute to the Valley’s PM2.5 attainment, and because additional ammonia controls are infeasible, the Valley’s

ammonia emissions do not need to be further reduced to address EPA’s PM2.5

standard.

3. Reasonable Further Progress

The requirement for reasonable further progress assures continual emissions reductions progress on the path to attainment. The Supplemental Document showsSJV

U APCD Governing Board

ITEM NUMBER 6: REVIEW AND APPROVE SIP ACTIONS IN RELATION TO THE 2006 PM2.5

STANDARD TO ADDRESS AIR QUALITY IMPACTS RESULTING FROM THE EXCEPTIONAL

WEATHER CONDITIONS CAUSED BY THE RECENT DROUGHT September 18, 2014

7 that the “generally linear process” demonstration in the 2012 PM2.5 Plan meets the “quantitative mil estone” requirement for reasonable further progress in 2014 and 2017 under subpart 4.

4. Contingency Measures

Contingency measures are extra emissions reductions that go into effect automatically without further regulatory action. T he contingency demonstra tion in

the 2012 PM2.5 Plan for 2014 and 2017 are still valid under subpart 4

.

5. New Source Review

On April 21, 2011, the District’s NSR rule (Rule 2201) was amended to address the

EPA’s PM2.5 nonattainment NSR permitting requirements of subpart 1. On June 2, 2014, EPA issued new requirements that subpart 4 be applie d to PM2.5 permitting programs by December 31, 2014

. However, EPA’s rulemaking clarifying NSR requirements for PM2.5 under subpart 4 is forthcoming, but, unfortunately, will not be proposed until late summer or fall of 2014. It is not expected to be finalized until several months thereafter. Waiting for EPA to fina lize its NSR rulemaking would not
allow the District sufficient time to meet the December 31, 2014 deadline. Rather than await EPA’s rulemaking and, as a result, missing federal rule development deadlines, the Supplemental D ocument describes how the Distr ict already satisfies subpart 4 requirements for NSR.

The 2011 amendments to District Rule 2201 already met subpart 4 requirements and major source thresholds for “Moderate” areas for NOx, SOx, and directly

emitted PM2.5. Subpart 4 requires nonattainm ent areas to address ammonia as a precursor unless it is determined that ammonia sources do not contribute significantly to PM concentrations. The District’s 2012 PM2.5 Plan demonstrates that control of ammonia emissions does not contribute significantly to PM2.5 attainment. Therefore, ammonia need not be addressed as a precursor to PM2.5 in the District’s NSR program.

NEXT STEPS AND THE NEED FOR INTEGRATED APPROACH :

The S upplemental D ocument demonstrates that the 2012 PM2.5 Plan satisfies all subpart 4 requirements and that attainment by 2015 is not practicable. The District can formally request that EPA approve the 2012 PM2.5 Plan and reclassify the Valley as a

“S erious ” area.

Upon reclassification by EPA, the District will face the following mand ates for new PM2.5 plans:SJV

U APCD Governing Board

ITEM NUMBER 6: REVIEW AND APPROVE SIP ACTIONS IN RELATION TO THE 2006 PM2.5

STANDARD TO ADDRESS AIR QUALITY IMPACTS RESULTING FROM THE EXCEPTIONAL

WEATHER CONDITIONS CAUSED BY THE RECENT DROUGHT September 18, 2014

8  1997 standard : The District intends to present a new attainment plan to your board for adoption in spring of 2015, showing attainment with the annual

standard of 15 μ g/m 3 by 2020.

 2006 standard : The District would have to adopt a new attainment plan within 18 months of EPA reclassification (for example, if the Valley is reclassified in early 2015, the plan would be due in mid

- 2016). This plan would have to show

attainment with the 24

- hour stand ard of 35 μ g/m 3 by 2019. An extension of up to 5 years (until 2024) would also be provided by law if necessary.

 2012 standard : The District would have to adopt a new attainment plan within 18 months of EPA designation, expected in late 2014. This would s et a plan due

date in mid

- 2016. If EPA classifies the Valley as Moderate, the initial attainment

deadline for this annual standard of 12 μ g/m 3 would be 2020. The District could request reclassification to Serious to set the attainment deadline to 2024. An extension of up to 5 years (until 2029) would also be provided by law if

necessary.

In addition to the above PM2.5 plans, the District also faces multiple requirements for developing attainment plans for ozone in the same timeframe. Efforts to attain these standards will involve regulatory and incentive based measures for the same pollutants and sources of air pollution. Also, much of the labor intensive preparatory work for developing these plans (such as emissions inventory and modeling) is common t o all plans and could potentially be streamlined and combined. Common sense dictates that we do our best to integrate these mandates and avoid redundancy and duplicative efforts. If approved by your Board, the District will pursue all administrative and legislative avenues to develop legal means and to garner EPA and ARB concurrence to

combine these efforts.

FISCAL IMPACT :

The development of the new plan will result in extensive added workload. No staffing

increase is recommended at this time to accommodate this increased workload. Pending the outcome of efforts to streamline the planning process for multiple standards, we may return to the Board for appropriations for additional resources if

necessary.

Attachment A : Resolution for Authorizing Submittal of the “Supplemental Document for

the 2012 PM2.5 Plan” to EPA (4 pages)

Attachment B : Supplemental Document for the 2012 PM2.5 Plan (63 pages)