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Wicher, Frances

From: Wicher, Frances

Sent: Friday, June 07, 2013 4:31 PM

To: 'Jessi Fierro'

Cc: Drake, Kerry; Steckel, Andrew; Hong, Jeanhee

Subject: Comments on the revised resolution & Quantification

Jessi, 

Thank you sharing the draft resolution for the “Quantification of Contingency Reductions for the 2008 PM2.5 Plan” (which we refer to as the 

Contingency Measure SIP). In reviewing this document together with the draft SIP, we have found several issues that will need to be addressed prior 

to its adoption. We are available Monday morning for a conference call if you would like to discuss the issues and our suggested revisions. 

1. The District is relying in part on SIP-creditable emission reductions that are schedule to occur in 2015. While we understand that the projects 

generating these reductions are already under contract, the Clean Air Act requirement that this SIP address requires emissions reductions in a 

future year (attainment contingency measures for the year 2015); therefore, the District is relying on emission reductions that are projected to 

occur from these projects in 2015 rather than actual reductions that have already occurred. In order for EPA to approve the use of these emission 

reductions to meet the CAA contingency measure requirement, the District will need to provide an enforceable commitment that meets the 

criteria identified in Section 7.0 of draft Rue 9610, including a commitment to a timely remedy should the reductions fail to occur in 2015 as 

projected. 

2. Please list the specific guidelines it is relying on to generate the projected SIP-creditable emission reductions in the Contingency Measure SIP 

instead of citing to section 3.1 of Rule 9610, since that section is still subject to change. The District should also include a copy of each of these 

guidelines in its SIP submittal. 

3. Please identify in the board resolution the specific amount of emission reductions that the District is committing to for meeting the contingency 

measure requirement and the year by which those reductions are to occur. 

4. Please include a specific date by which any action necessary for remedying a shortfall will be completed. 

We suggest the following language could be included in the resolution to address these issues. This language would replace paragraph 3. We also 

suggest similar language be included in the Contingency Measure SIP. 
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3. Consistent with the requirements of Section 7.0 of District Proposed New Rule 9610, the District Governing Board hereby commits to: 

a. Use the following incentive program guidelines to quantify SIP-creditable emission reductions relied upon to satisfy the PM2.5 

contingency measure requirement for 2015: NRCS [title/date] and Carl Moyer [title/date]. 

b. Achieve 4.15 tons per day (tpd) of NOx reductions and 0.10 tpd of PM2.5 reductions from these incentive programs by 2015. 

These amounts of emission reductions do not exceed the amount projected to be achieved through the use of secured or reasonably 

anticipated incentive program funding and the estimated availability of emission reductions projects and willing participants, based on 

historical participation and estimates of remaining equipment. 

c. Account for these specific amounts of NOx and PM2.5 emission reductions in annual demonstration reports as SIP-creditable 

emission reductions are achieved through provisions of Rule 9610. This emissions reduction commitment is, through this resolution and 

after public hearing, authorized by the District for inclusion in the SIP and will be specifically accounted for in the 2014 Annual 

Demonstration Report. 

d. Determine, as part of the 2014 Annual Demonstration Report, whether the 4.15 tpd of NOx reductions and 0.10 tpd of PM2.5 

reductions identified above will occur by 2015 as projected. If either the District or EPA finds that there is a SIP shortfall for 2015, the 

District will adopt and submit to EPA, no later than [DATE], substitute rules and measures that will achieve equivalent emission 

reductions as expeditiously as practicable and no later than any applicable implementation deadline in the CAA or EPA’s implementing 

regulations. 

Separate from the above issues, as we have discussed, EPA also has concerns about the documenting the basis for the proposed 9:1 NOx to 

PM2.5 interpollutant trading ratio. As part of our action on the 2008 PM2.5 plan, we approved the use of a 9:1 NOx to PM2.5 trading ratio but only for 

use in transportation conformity determinations and for no other purposes. Final TSD, p. 46. The method used to set this ratio involved modeling 

“across the board” emission changes over the entire modeling domain. While we acknowledged that this method appeared to be adequate for 

assessing the effect of domain-wide emissions changes, we also cautioned that trading in other context could involve additional consideration of 

spatial and temporal variation of the emissions and would require an additional technical demonstration by the state and evaluation by EPA. Final 

TSD, p. 46. The Contingency Measure SIP now proposes to use this 9:1 ratio in a specific context: substituting wintertime direct PM2.5 reductions 

from woodburning restrictions for unspecified regional year-around reductions of NOx. An evaluation is needed of why the 9:1 ratio is appropriate 
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in this context or why the original demonstration submitted with the 2008 plan remains valid. We will be glad to discuss this further with you and 

ARB. 

Frances 

___________________ 

 Frances Wicher 

 (415) 972-3957 

 wicher.frances@epa.gov

 Air Planning Office (AIR-2) 

 U.S. EPA - Region 9 

 75 Hawthorne Street 

 San Francisco, California 94105 

________________________________ 

From: Jessi Fierro [mailto:Jessica.Fierro@valleyair.org] 

Sent: Thursday, June 06, 2013 3:19 PM 

To: Wicher, Frances 

Subject: revised resolution 

I made some revisions to the resolution in the section about Rule 9610 requirements.