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: SJVUAPCD Governing Board

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

RECOMMENDATIONS:

1. Direct 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, the D.C. Circuit Court ruled that EPA erred by using Clean Air 

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

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 

District’s Supplemental Document demonstrates 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 

events” 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 new 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 drought are also impacting the Valley under EPA’s 2006 

PM2.5 standard, which was set at 35 μg/m3as 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 subpart 

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 attainment date at 2015. 
SJVUAPCD 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. Department 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 98th

percentile values, which are amongst the highest values recorded over the course of 

the calendar year. Although the 98th percentile values were on the decline in 2012, 

2013 values are so high that attainment in 2015 (based on 2013-2015 data) is 

impossible. As illustrated in Table 2, with conservative assumptions for

concentrations in 2014, it is impossible 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 1953
SJVUAPCD 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

1999-20002000-20012001-20022002-20032003-20042004-20052005-20062006-20072007-20082008-20092009-20102010-20112011-20122012-20132013-2014

T850MB Stability Parameter ( ̊C)
SJVUAPCD 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

5

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

2013-2015 Data) is Impossible

Site

98

th

Percentile Values

Measured Values Hypothetical Values

2012

Progress 

towards 

attainment 

2013

Exceptional 

weather impacts

2014

Projected, 

based on 

exceptional 

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, an 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 emissions 

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 noted 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:
SJVUAPCD 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

6

 Continued implementation of the over 500 rules and rule amendments 

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 Plan already included extensive scientific analysis demonstrating that 

ammonia and VOC reductions do not contribute to attainment. For example, it 

would take a total ammonia reduction of 125 tons per day – 34% of 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 relationship 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 healthbased 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 ammonia 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 shows 
SJVUAPCD 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 milestone” 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. The contingency demonstration 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 applied 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 finalize 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 Document describes how the District 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 directlyemitted PM2.5. Subpart 4 requires nonattainment 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 Supplemental Document 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 

“Serious” area. 

Upon reclassification by EPA, the District will face the following mandates for new 

PM2.5 plans:
SJVUAPCD 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 μg/m3by 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 standard of 35 μg/m3by 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 set a plan due 

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

deadline for this annual standard of 12 μg/m3 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 to 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)