Appendix E 

Potential Impacts of State Strategy Proposed New Measures 
 

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May 7, 2007 Appendix E 1 

ENVIRONMENTAL IMPACT ANALYSIS 

Introduction

The control measures proposed in the State Strategy were developed for the 

purpose of improving air quality in California. However, as these measures are 

developed into rules and regulations and subsequently implemented, there is 

potential for them to have an adverse environmental impact on other natural 

resources. The California Environmental Quality Act (CEQA) and ARB policy 

requires an analysis to determine any potentially adverse environmental impacts 

that may result from adoption of these measures. This appendix presents an 

analysis of potential impacts and also identifies mitigation measures that can be 

implemented to offset any potentially significant impacts. The appendix contains 

three parts: an environmental review checklist, descriptions of cumulative 

impacts of the State Strategy, and a description of each measure’s potential 

adverse environmental impacts. 

California Environmental Quality Act

The California Secretary for Resources has determined that ARB meets the 

criteria for a Certified State Regulatory Program (Public Resources Code Section 

21080.5). This certification allows ARB to adopt rules, regulations, standards 

and plans but exempts it from the requirement to prepare Initial Studies, Notices 

of Preparation, Negative Declarations or Environmental Impact Reports (EIRs). 

As a certified agency, however, ARB is required to prepare a substitute 

document which is subject to other provisions of CEQA such as avoiding 

significant adverse effects on the environment where feasible. This appendix 

considers cumulative impacts and addresses adverse activities and impacts 

associated with the proposed measures. As required by CEQA, there will be a 

45-day public comment period at which time the public can review and comment 

on this analysis. ARB will respond in writing to all significant environmental 

concerns raised by the public during this comment period and also at the Board 

Hearing. 

Scope of Analysis

The scope of the analysis is intended to help focus public review and to assure 

that any questions and comments are appropriate and meaningful. This 

appendix specifically focuses on potential adverse environmental impacts. The 

remainder of the report emphasizes positive environmental benefits that the 

proposed strategies will have on air quality which is the purpose and goal of the 

State Strategy. 

This appendix cannot and does not contain a detailed, quantitative impact 

analysis for each of the control measures in the State Strategy. Because the 

State Strategy identifies proposed future actions to adopt and implement 
May 7, 2007 Appendix E 2 

emission reduction regulations for which specific regulatory language has not yet 

been developed, the analysis is necessarily general and qualitative. When a 

proposed measure is developed and proposed in regulatory format, it will be a 

process with full public participation. Proposed regulations will undergo a 

detailed environmental analysis as required by CEQA, will be discussed at public 

workshops, and will go through the public hearing process as required by law 

(see the Administrative Procedure Act, Gov. Code section 11340 et seq.). When 

specific regulatory language is developed, it will be possible to analyze potential 

environmental impacts in detail. For example, the scope of the impacted 

population of any given controlled emission source will become further refined 

during regulatory development. Additionally, cumulative impacts were 

considered for the State Strategy, recognizing these measures are likely to have 

various phase-in dates. In this appendix, potential environmental impacts are 

identified to the extent currently feasible. 

Environmental Checklist

An environmental checklist was used to identify and evaluate potential 

cumulative impacts of the measures proposed in the State Strategy. The 

environmental effects checked below indicate those that may be affected by the 

proposed measures. Further discussion will follow regarding the impacts that 

strategies may have and potential mitigation strategies that can be implemented 

to lessen the impacts. 

 Aesthetics Air Quality Agricultural 

 Resources 

 Biological Resources Cultural Resources Energy Demand 

 Geology and Soils Hazards/ 

 Hazardous Material Land Use/Planning 

 Mineral Resources Noise Population and 

 Housing 

 Public Services Recreation Solid/Hazardous 

 Waste 

 Transportation/Traffic Water Quality Mandatory Findings 
May 7, 2007 Appendix E 3 

Evaluation of Cumulative Environmental Impacts

Potentially 

Significant 

Impact 

Less Than 

Significant 

Impact 

No 

Impact

I. AESTHETICS. Would the project: 

a) Have a substantial adverse effect on a 

scenic vista? 

b) Substantially damage scenic resources, 

including, but not limited to, trees, rock 

outcroppings, and historic buildings within a 

state scenic highway? 

c) Substantially degrade the existing visual 

character or quality of the site and its 

surroundings? 

d) Create a new source of substantial light 

or glare which would adversely affect day 

or nighttime views in the area? 

II. AIR QUALITY. Would the project: 

a) Conflict with or obstruct implementation 

of the applicable air quality plan? 

b) Violate any air quality standard or 

contribute substantially to an existing or 

projected air quality violation? 

c) Result in a cumulatively considerable net 

increase of any criteria pollutant for which 

the project region is non-attainment under 

an applicable federal or state ambient air 

quality standard (including releasing 

emissions which exceed quantitative 

thresholds for ozone precursors)? 

d) Expose sensitive receptors to substantial 

pollutant concentrations? 

e) Create objectionable odors affecting a 

substantial number of people? 
May 7, 2007 Appendix E 4 

Potentially 

Significant 

Impact 

Less Than 

Significant 

Impact 

No 

Impact

III. AGRICULTURE RESOURCES. Would 

the project: 

a) Convert Prime Farmland, Unique 

Farmland, or Farmland of Statewide 

Importance (Farmland), as shown on the 

maps prepared pursuant to the Farmland 

Mapping and Monitoring Program of the 

California Resources Agency, to nonagricultural use? 

b) Conflict with existing zoning for 

agricultural use, or a Williamson Act 

contract? 

c) Involve other changes in the existing 

environment which, due to their location or 

nature, could result in conversion of 

Farmland, to non-agricultural use? 

IV. BIOLOGICAL RESOURCES. Would 

the project: 

a) Have a substantial adverse effect, either 

directly or through habitat modifications, on 

any species identified as a candidate, 

sensitive, or special status species in local 

or regional plans, policies, or regulations, 

or by the California Department of Fish and 

Game or U.S. Fish and Wildlife Service? 

b) Have a substantial adverse effect on any 

riparian habitat or other sensitive natural 

community identified in local or regional 

plans, policies, regulations or by the 

California Department of Fish and Game or 

US Fish and Wildlife Service? 

c) Have a substantial adverse effect on 

federally protected wetlands as defined by 

Section 404 of the Clean Water Act 

(including, but not limited to, marsh, vernal 

pool, coastal, etc.) through direct removal, 
May 7, 2007 Appendix E 5 

Potentially 

Significant 

Impact 

Less Than 

Significant 

Impact 

No 

Impact

filling, hydrological interruption, or other 

means? 

d) Interfere substantially with the 

movement of any native resident or 

migratory fish or wildlife species or with 

established native resident or migratory 

wildlife corridors, or impede the use of 

native wildlife nursery sites? 

e) Conflict with any local policies or 

ordinances protecting biological resources, 

such as a tree preservation policy or 

ordinance? 

f) Conflict with the provisions of an adopted 

Habitat Conservation Plan, Natural 

Community Conservation Plan, or other 

approved local, regional, or state habitat 

conservation plan? 

V. CULTURAL RESOURCES. Would the 

project: 

a) Cause a substantial adverse change in 

the significance of a historical resource as 

defined in '15064.5? 

b) Cause a substantial adverse change in 

the significance of an archaeological 

resource pursuant to '15064.5? 

c) Directly or indirectly destroy a unique 

paleontological resource or site or unique 

geologic feature? 

d) Disturb any human remains, including 

those interred outside of formal 

cemeteries? 

VI. ENERGY DEMAND. Would the project:

a) Conflict with adopted energy 

conservation plans? 

b) Result in the need for new or 
May 7, 2007 Appendix E 6 

Potentially 

Significant 

Impact 

Less Than 

Significant 

Impact 

No 

Impact

substantially altered power or natural gas 

utility systems? 

c) Create any significant effects on peak 

and base period demands for electricity 

and other forms of energy? 

d) Comply with existing energy standards? 

VII. GEOLOGY AND SOILS. Would the 

project: 

a) Expose people or structures to potential 

substantial adverse effects, including the 

risk of loss, injury, or death involving: 

 

i) Rupture of a known earthquake fault, as 

delineated on the most recent AlquistPriolo Earthquake Fault Zoning Map issued 

by the State Geologist for the area or 

based on other substantial evidence of a 

known fault? Refer to Division of Mines and 

Geology Special Publication 42. 

ii) Strong seismic ground shaking? 

iii) Seismic-related ground failure, including 

liquefaction? 

iv) Landslides? 

b) Result in substantial soil erosion or the 

loss of topsoil? 

c) Be located on a geologic unit or soil that 

is unstable, or that would become unstable 

as a result of the project, and potentially 

result in on- or off-site landslide, lateral 

spreading, subsidence, liquefaction or 

collapse? 

d) Be located on expansive soil, as defined 

in Table 18-1-B of the Uniform Building 

Code (1994), creating substantial risks to 

life or property? 

 
May 7, 2007 Appendix E 7 

Potentially 

Significant 

Impact 

Less Than 

Significant 

Impact 

No 

Impact

e) Have soils incapable of adequately 

supporting the use of septic tanks or 

alternative waste water disposal systems 

where sewers are not available for the 

disposal of waste water? 

VIII. HAZARDS AND HAZARDOUS 

MATERIALS. Would the project: 

a) Create a significant hazard to the public 

or the environment through the routine 

transport, use, or disposal of hazardous 

materials? 

b) Create a significant hazard to the public 

or the environment through reasonably 

foreseeable upset and accident conditions 

involving the release of hazardous 

materials into the environment? 

c) Be located on a site which is included on 

a list of hazardous materials sites compiled 

pursuant to Government Code Section 

65962.5 and, as a result, would it create a 

significant hazard to the public or the 

environment? 

d) For a project located within an airport 

land use plan or, where such a plan has 

not been adopted, within two miles of a 

public airport or public use airport, would 

the project result in a safety hazard for 

people residing or working in the project 

area? 

e) For a project within the vicinity of a 

private airstrip, would the project result in a 

safety hazard for people residing or 

working in the project area? 

f) Impair implementation of or physically 

interfere with an adopted emergency 

response plan or emergency evacuation 

plan? 

 
May 7, 2007 Appendix E 8 

Potentially 

Significant 

Impact 

Less Than 

Significant 

Impact 

No 

Impact

g) Expose people or structures to a 

significant risk of loss, injury or death 

involving wildland fires, including where 

wildlands are adjacent to urbanized areas 

or where residences are intermixed with 

wildlands? 

IX. LAND USE AND PLANNING. Would 

the project: 

a) Physically divide an established 

community? 

b) Conflict with any applicable land use 

plan, policy, or regulation of an agency with 

jurisdiction over the project (including, but 

not limited to the general plan, specific 

plan, local coastal program, or zoning 

ordinance) adopted for the purpose of 

avoiding or mitigating an environmental 

effect? 

c) Conflict with any applicable habitat 

conservation plan or natural community 

conservation plan? 

X. MINERAL RESOURCES. Would the 

project: 

a) Result in the loss of availability of a 

known mineral resource that would be of 

value to the region and the residents of the 

state? 

b) Result in the loss of availability of a 

locally-important mineral resource recovery 

site delineated on a local general plan, 

specific plan or other land use plan? 

XI. NOISE. Would the project result in: 

a) Exposure of persons to or generation of 

noise levels in excess of standards 

established in the local general plan or 

noise ordinance, or applicable standards of 
May 7, 2007 Appendix E 9 

Potentially 

Significant 

Impact 

Less Than 

Significant 

Impact 

No 

Impact

other agencies? 

b) Exposure of persons to or generation of 

excessive groundborne vibration or 

groundborne noise levels? 

c) A substantial permanent increase in 

ambient noise levels in the project vicinity 

above levels existing without the project? 

d) A substantial temporary or periodic 

increase in ambient noise levels in the 

project vicinity above levels existing without 

the project? 

e) For a project located within an airport 

land use plan or, where such a plan has 

not been adopted, within two miles of a 

public airport or public use airport, would 

the project expose people residing or 

working in the project area to excessive 

noise levels? 

f) For a project within the vicinity of a 

private airstrip, would the project expose 

people residing or working in the project 

area to excessive noise levels? 

XII. POPULATION AND HOUSING. 

Would the project: 

 

a) Induce substantial population growth in 

an area, either directly (for example, by 

proposing new homes and businesses) or 

indirectly (for example, through extension 

of roads or other infrastructure)? 

b) Displace substantial numbers of existing 

housing, necessitating the construction of 

replacement housing elsewhere? 

c) Displace substantial numbers of people, 

necessitating the construction of 

replacement housing elsewhere? 
May 7, 2007 Appendix E 10 

Potentially 

Significant 

Impact 

Less Than 

Significant 

Impact 

No 

Impact

XIII. PUBLIC SERVICES. 

a) Would the project result in substantial 

adverse physical impacts associated with 

the provision of new or physically altered 

governmental facilities, need for new or 

physically altered governmental facilities, 

the construction of which could cause 

significant environmental impacts, in order 

to maintain acceptable service ratios, 

response times or other performance 

objectives for any of the public services: 

Fire protection? 

Police protection? 

Schools? 

Parks? 

Other public facilities? 

XIV. RECREATION 

a) Would the project increase the use of 

existing neighborhood and regional parks 

or other recreational facilities such that 

substantial physical deterioration of the 

facility would occur or be accelerated? 

b) Does the project include recreational 

facilities or require the construction or 

expansion of recreational facilities which 

might have an adverse physical effect on 

the environment? 

XV. SOLID/HAZARDOUS WASTE. Would 

the project: 

 

a) Be served by a landfill with sufficient 

permitted capacity to accommodate the 

project’s solid waste disposal needs? 
May 7, 2007 Appendix E 11 

Potentially 

Significant 

Impact 

Less Than 

Significant 

Impact 

No 

Impact

b) Comply with federal, state, and local 

statutes and regulations related to solid 

and hazardous waste? 

XVI. TRANSPORTATION/TRAFFIC. 

Would the project: 

a) Cause an increase in traffic which is 

substantial in relation to the existing traffic 

load and capacity of the street system (i.e., 

result in a substantial increase in either the 

number of vehicle trips, the volume to 

capacity ratio on roads, or congestion at 

intersections)? 

b) Exceed, either individually or 

cumulatively, a level of service standard 

established by the county congestion 

management agency for designated roads 

or highways? 

c) Result in a change in air traffic patterns, 

including either an increase in traffic levels 

or a change in location that results in 

substantial safety risks? 

d) Substantially increase hazards due to a 

design feature (e.g., sharp curves or 

dangerous intersections) or incompatible 

uses (e.g., farm equipment)? 

e) Result in inadequate emergency 

access? 

f) Result in inadequate parking capacity? 

g) Conflict with adopted policies, plans, or 

programs supporting alternative 

transportation (e.g., bus turnouts, bicycle 

racks)? 

 
May 7, 2007 Appendix E 12 

Potentially 

Significant 

Impact 

Less Than 

Significant 

Impact 

No 

Impact

XVII. WATER QUALITY. Would the 

project: 

 

a) Violate any water quality standards or 

waste discharge requirements? 

b) Substantially deplete groundwater 

supplies or interfere substantially with 

groundwater recharge such that there 

would be a net deficit in aquifer volume or a 

lowering of the local groundwater table 

level (e.g., the production rate of preexisting nearby wells would drop to a level 

which would not support existing land uses 

or planned uses for which permits have 

been granted)? 

c) Substantially alter the existing drainage 

pattern of the site or area, including 

through the alteration of the course of a 

stream or river, in a manner which would 

result in substantial erosion or siltation onor off-site? 

d) Substantially alter the existing drainage 

pattern of the site or area, including 

through the alteration of the course of a 

stream or river, or substantially increase 

the rate or amount of surface runoff in a 

manner which would result in flooding onor off-site? 

e) Create or contribute runoff water which 

would exceed the capacity of existing or 

planned stormwater drainage systems or 

provide substantial additional sources of 

polluted runoff? 

f) Otherwise substantially degrade water 

quality? 

g) Place housing within a 100-year flood 

hazard area as mapped on a federal Flood 

Hazard Boundary or Flood Insurance Rate 
May 7, 2007 Appendix E 13 

Potentially 

Significant 

Impact 

Less Than 

Significant 

Impact 

No 

Impact

Map or other flood hazard delineation 

map? 

h) Place within a 100-year flood hazard 

area structures which would impede or 

redirect flood flows? 

i) Expose people or structures to a 

significant risk of loss, injury or death 

involving flooding, including flooding as a 

result of the failure of a levee or dam? 

j) Inundation by seiche, tsunami, or 

mudflow? 

XVIII. MANDATORY FINDINGS OF 

SIGNIFICANCE 

a) Does the project have the potential to 

degrade the quality of the environment, 

substantially reduce the habitat of a fish or 

wildlife species, cause a fish or wildlife 

population to drop below self-sustaining 

levels, threaten to eliminate a plant or 

animal community, reduce the number or 

restrict the range of a rare or endangered 

plant or animal or eliminate important 

examples of the major periods of California 

history or prehistory? 

b) Does the project have impacts that are 

individually limited, but cumulatively 

considerable? ("Cumulatively 

considerable" means that the incremental 

effects of a project are considerable when 

viewed in connection with the effects of 

past projects, the effects of other current 

projects, and the effects of probable future 

projects)? 

c) Does the project have environmental 

effects which will cause substantial adverse 

effects on human beings, either directly or 

indirectly? 
May 7, 2007 Appendix E 14 

Cumulative Potential Adverse Environmental Impacts

Each environmental effect outlined in the environmental checklist is further 

described below. A detailed reference table at the end of this section identifies 

each measure in the State Strategy, any potential adverse environmental 

impacts, and potential mitigation measures. 

Several proposed measures are currently in the process of rule development and 

may have a more detailed assessment of potential significant impacts. However, 

for the less developed strategies, we have attempted to include any potential 

impact that reasonably could occur given current knowledge. 

I. Aesthetics 

Cumulative Impact: No element of the State Strategy is expected to degrade the 

natural beauty of California. Instead, the State Strategy will have significant 

positive impacts on aesthetics. Regional haze is expected to be reduced by 

State Strategy elements that reduce hydrocarbon, nitrogen oxide, and particulate 

matter emissions. 

II. Air Quality 

Cumulative Impact: ARB staff believes the cumulative impact of the State 

Strategy is to substantially improve air quality, however there are potentially 

significant impacts to air quality. Some strategies may involve trade-offs, where 

emissions of one pollutant may increase slightly in order to more effectively 

reduce overall emissions and protect public health. 

The four major types of impacts that were considered are related to criteria 

pollutants, air toxics, greenhouse gases, and stratospheric ozone depleting 

pollutants. 

 Criteria Pollutants 

Potentially significant impacts on criteria pollutant emissions may occur due to: 

selective catalytic reduction processes, use of diesel particulate filters, and 

production and consumption of low-sulfur diesel fuel. However, the cumulative 

impact of the State Strategy is to reduce emissions of major criteria pollutants 

(ROG, NOx, SOx, and PM2.5). 

Selective Catalytic Reduction — Measures in the State Strategy to reduce NOx 

from diesel-fueled engines may necessitate use of Selective Catalytic Reduction 

(SCR). For on-road heavy-duty diesel vehicles in particular, SCR is the preferred 

emission control strategy for meeting the NOx emission requirements for the 

2010 model year. The use of SCR in light-duty diesel vehicles is also being 

considered by auto manufacturers. SCR reduces NOx into molecular nitrogen 
May 7, 2007 Appendix E 15 

and water by injecting urea into the exhaust upstream of a catalyst. SCR 

catalysts function well only within a narrow temperature window, and control 

systems must be in place to keep the exhaust temperature within an optimum 

range. If exhaust temperatures are too high, the SCR catalyst can be 

deactivated or fail. If exhaust temperatures are too low, or too much reductant 

(usually urea) is used, ammonia can become an exhaust byproduct (called 

“ammonia slip”) and can be emitted to the atmosphere. Ammonia slip can 

worsen as the catalyst ages and becomes less effective. 

Diesel Particulate Filters — A number of measures in the State Strategy would 

require the use of diesel particulate filters, add-on devices that are mounted on 

the exhaust pipe. Certain types of these diesel particulate filters, referred to as 

passive filters, accelerate the conversion of nitric oxide (NO) to nitrogen dioxide 

(NO2). As such, there is a potential for an adverse effect on the concentration 

and location of peak ozone levels in the State, especially near centers of diesel 

activity. 

Catalyst manufacturers are aware of the issue, and preliminary analysis suggests 

that the impacts may be mitigated by designing the system to limit the NO to NO2

conversion rates. In the near term, the advantages of putting diesel particulate 

filters into operation to reduce risk from diesel PM and allowing the technology to 

develop and mature should offset any limited adverse impacts. 

Reformulated Gasoline — The purpose of this strategy is to offset or eliminate 

excess evaporative emissions caused by ethanol permeation through fuel lines 

and tanks. Reformulating gasoline may require more feedstock and/or more 

processing which means that impacts associated with this measure could come 

from an increased demand on refineries. However, air district permitting 

programs will evaluate and mitigate the air quality and environmental impacts to 

the extent feasible. 

Cold Ironing (Shore-side Power) — This process allows ships to run heating, 

air conditioning, lights and other operations by plugging into shore-side electrical 

power. This reduces emissions by allowing ships to shut down the uncontrolled 

auxiliary engines which traditionally have powered these electric-based activities. 

There are criteria pollutant emissions associated with the incremental electricity 

generation from power plants, but they are significantly less than emissions 

generated by ship engines. 

Low Sulfur Diesel Fuel — Low sulfur diesel fuel requires increased 

hydrotreating of fuel to remove sulfur, which requires increased hydrogen 

production. Hydrogen production, from petroleum feedstock, has the potential to 

increase criteria pollutants (particularly NOx) and CO2 emissions. The most 

acute impact of any emissions increase could be in the communities near 

refineries, however, air district permitting programs will evaluate and mitigate the 

air quality and environmental impacts to the extent feasible. 
May 7, 2007 Appendix E 16 

Electrification of Equipment — Electric forklifts, dockside electrical hookups for 

larger marine vessels, and other strategies may incrementally increase electricity 

demand from power plants. The increase in power production will have an 

incidental increase in emissions (primarily NOx) from power plants. Air district 

permitting programs are in place to limit these emission increases. Overall, 

emissions should decrease significantly as fuels such as diesel and propane are 

replaced by the much cleaner natural gas burned at well-controlled power plants. 

Locomotives — Diesel oxidation catalysts (DOCs) operating under high loads 

and temperatures can increase SO2 to SO4 formation. Locomotives fueled out 

of state will use non-road diesel fuel with sulfur levels lowered from 5,000 to 500 

ppmw on June 1, 2007. However, since most refueling for interstate locomotives 

occurs in-state, and locomotives in California typically use ultra low sulfur diesel 

(<15 ppmw), this is not a significant source of SOx. SOx is emitted in direct 

proportion to the diesel fuel sulfur content. 

Vehicle Retirement Program — Scrapping retired vehicles involves the use of 

heavy-duty equipment to crush vehicles and then transport the recyclable 

materials to markets which often times are located overseas. The increased 

processing and transport of the scrapped materials could create additional 

emissions, however, the State Strategy also includes measures to reduce 

emissions from ships and heavy-duty off-road equipment. The benefit of retiring 

high-polluting vehicles greatly outweighs the emissions from processing. 

 Air Toxics 

Potentially significant air toxics impacts could occur due to reformulation of 

consumer products and the use of alternative fuels, alternative fuel additives and 

alternative aftertreatment systems. However, any new formulations of these 

products and additives would be closely scrutinized to prevent the addition of 

toxic compounds. These potential impacts will be greatly offset by the 

substantial reductions in toxics from diesel engines required by the State 

Strategy. The cumulative impact of the State Strategy is to greatly reduce 

emissions of toxic compounds. A brief description of potential impacts of the 

strategies is provided below. 

Selective Catalytic Reduction — Since SCR technology represents a 

significant departure from conventional emission controls deployed on motor 

vehicles, there is the potential for these systems to emit new toxic substances 

that have not been readily observed in previous studies, and/or exhibit an 

increase in some currently emitted toxic substances due to urea-related 

chemistry. Such secondary emissions are likely to include organonitrogen 

compounds, many of which are listed as toxic air contaminants (TAC) and are 

carcinogenic. 
May 7, 2007 Appendix E 17 

Vehicle Retirement Program — High-mileage and older vehicles are likely 

candidates for scrappage. Their deterioration leads to increased emissions. 

Once vehicles are scrapped, they can no longer pollute. However, vehicles 

commonly contain lead, chromium and mercury which may be released during 

the scrapping process. These toxic air pollutants have potential to have an 

adverse impact on air and water quality if not properly handled. For example, 

mercury switches used in hood and trunk lighting can be recovered rather than 

being crushed. Auto dismantlers are regulated by the Department of Toxic 

Substance Control (CCR, Title 22). 

Cold Ironing (Shore-side Power) — This process allows ships to run heating, 

air conditioning, lights and other operations by plugging into shore-side electrical 

power. This reduces emissions by allowing ships to shut down the uncontrolled 

auxiliary engines which traditionally have powered these electric-based activities. 

There are toxic air contaminants associated with incremental electricity 

generation at power plants, but they are significantly less than emissions 

generated by ship engines. 

Consumer Products — The consumer products measures require reformulation 

to reduce VOC content. A number of VOCs currently used in consumer product 

formulations, such as ethylene-based glycol ethers, trichloroethylene (TCE), and 

toluene, have also been identified as toxic air contaminants. When a product is 

reformulated to meet new VOC limits, however, a manufacturer could use small 

amounts of a chemical, not used before, that may be a toxic air pollutant. This 

potential impact will need to be evaluated and mitigated as reformulation options 

are reviewed during the development of new VOC limits, as staff has done in 

previous rulemakings. 

Two particular toxic air contaminants (TAC) used in some consumer products, 

methylene chloride (MeCl) and perchloroethylene (Perc), are specifically 

exempted from the VOC definition because of their very low ozone-forming 

capabilities. As a result, some manufacturers may choose to use MeCl or Perc 

in their reformulations to reduce the VOC content in meeting future limits. 

However, when setting new VOC limits, staff analyzes the potential use of nonVOC TACs as reformulation options to ensure protection of public health. To 

avoid increased use of non-VOC TACs, staff sets emissions standards that are 

commercially and technologically feasible without use of TACs or bans TACs in 

the category at hand. Staff has prohibited three TACs—MeCl, Perc, and TCE—

in approximately 56 categories to date, and will consider prohibiting their use in 

other categories, if feasible. 

Cleaner Main Ship Engines — Various technologies can be used to reduce 

NOx emissions from main ship engines such as low-NOx fuel injectors, delayed 

injection timing and technologies that add water vapor to the combustion 

chamber. Impacts associated with technologies include slight increases in PM, 
May 7, 2007 Appendix E 18 

hydrocarbons and CO2. Additionally, there may be increased PM levels 

associated with selective catalytic reduction. 

Fuel Additives — Fuel additives or reformulation of fuels may provide possible 

emission reduction benefits. However, fuel additives or fuel reformulation may 

also create adverse emissions and environmental impacts. Before a fuel additive 

or fuel reformulation is implemented as an emission reduction strategy, a 

multimedia evaluation must be conducted under California Health and Safety 

Code Section 43830.8. This evaluation will assess the potential emission impact 

associated with any additive or fuel reformulation to the environment and public 

health. 

 Greenhouse Gases 

Potentially significant greenhouse gas emissions could result from measures that 

may reduce fuel efficiency or increase energy use, and consumer product rules. 

Diesel-Fueled Engines — Proposed measures to reduce emissions from dieselfueled engines could require the use of new diesel engines, engine modifications, 

add-on control devices such as diesel particulate filters, oxidation catalysts and 

selective catalytic reduction (SCR) systems, low-sulfur diesel fuel, alternative fuel 

formulations, or other strategies. These strategies have the potential to slightly 

reduce fuel economy and increase greenhouse gas emissions. These impacts 

may be mitigated as other engine features become more efficient to meet air 

pollution emission standards and by reducing idling times for trucks and other 

mobile equipment. 

Diesel Particulate Filters — A number of measures in the State Strategy would 

require the use of diesel particulate filters. These particulate filters must be 

periodically regenerated by burning off the accumulated carbon and associated 

hydrocarbons trapped on the filter. Active regeneration methods use external 

fuel or energy to heat the filter and regenerate it. 

Cleaner Main Ship Engines — Various technologies can be used to retrofit 

main ship engines such as low-NOx fuel injectors, delayed injection timing and 

technologies that add water vapor to the combustion chamber. Impacts 

associated with technologies include slight increases in PM, hydrocarbons and 

CO2. Additionally, there may be increased PM levels associated with selective 

catalytic reduction. 

Consumer Products — Alternative compounds used to meet lower VOC limits 

in the State Strategy’s consumer products measures could be greenhouse 

gases. For aerosol products to meet the VOC limits in the proposed regulations, 

manufacturers may choose to replace some or all of the typical hydrocarbon 

propellants, such as propane and butane, with the hydrofluorocarbons HFC-152a 

or HFC-134a, or carbon dioxide (CO2), which are greenhouse gases. HFC-152a 
May 7, 2007 Appendix E 19 

and HFC-134a have no ozone depletion potential, do not contribute to the 

formation of ground-level ozone, are low in toxicity, and are less flammable. In 

addition, HFC-152a has the lowest global warming potential of all the HFCs and 

an atmospheric lifetime of only 1.5 years. While HFC-134a has significantly 

higher global warming potential than HFC-152a, its use is quite limited. Because 

HFC-134a has such low flammability, it is typically only used in consumer 

product applications where flammability is a significant concern. Due to the high 

cost of HFC-152a and HFC-134a (as much as five to seven times greater than 

other hydrocarbon propellants, such as propane and butance), it is anticipated 

that manufacturers will use as little HFC-152a or HFC-134a as possible when 

reformulating their aerosol products. Consequently, because these measures 

would not cause a significant increase in the use of HFC-152a or HFC-134a, 

there would be a negligible global warming impact. However, further analysis of 

the properties and effects of these HFCs is needed. If the analysis reveals 

significant impacts, ARB staff would reassess the control strategy. CO2 used as 

a replacement for hydrocarbon propellants would be a recycled byproduct from 

existing processes and would not create an increase in global warming gases. 

Stratospheric Ozone Depleting Pollutants 

Consumer Products — Some hydrochlorofluorocarbons are still used in a very 

small number of consumer products as solvent. HCFC-22 is also used as a 

blowing agent in some foam insulation sealant products because of its low 

flammability. HCFCs are exempt VOCs under the existing and proposed 

regulations. It is unknown if there will be an increased use of these compounds 

in meeting lower VOC limits. However, all HCFCs are classified as group II 

ozone-depleting compounds by U.S. EPA and are scheduled for phase out by 

2030. Because of the phase out, manufacturers are very likely to use blowing 

agents and solvents other than HCFCs. We therefore anticipate that the impact 

on ozone depletion due to HCFCs will be negligible. 

Vehicle Retirement Program — Auto dismantlers that receive end-of-life 

vehicles with air conditioning systems must remove any refrigerant contained in 

these systems. During the removal of the refrigerant, there is potential for an 

incidental amount of refrigerant to escape into the atmosphere. Once the 

refrigerant is removed, it must be taken to a registered facility for proper 

handling. 

III. Agricultural Resources 

Cumulative Impact: The State Strategy is not expected to cause any adverse 

impacts on the agricultural resources of California. Ozone pollution causes 

significant crop yield loss in California. The State Strategy will help reduce ozone 

levels and consequently reduce crop loss resulting from ozone damage. 

A discussion of potential environmental impacts associated Department of 

Pesticide Regulation’s 2008 Pesticide Element is at the end of this section. 
May 7, 2007 Appendix E 20 

IV. Biological Resources 

Cumulative Impact: The State Strategy is not expected to cause any adverse 

impacts on the biological resources of California. We believe that the proposed 

measures will improve air quality and consequently, will improve the habitat of 

our biological resources. 

V. Cultural Resources 

Cumulative Impact: The State Strategy is not expected to cause any adverse 

impacts on the cultural resources of California. We believe that the proposed 

measures will reduce ozone and acidic compounds in the air. Ozone, which 

causes oxidation, and airborne acids are both known to cause deterioration of 

archaeological, paleontological, and geological features. 

VI. Energy Demand 

Cumulative Impact: As energy demand increases as a result of the State 

Strategy, there is a potential for significant adverse environmental impacts. 

These impacts can be mitigated through energy conservation programs, using 

renewable energy sources, and designing engine control systems to maximize 

fuel efficiencies. 

Several State Strategies involve electrification of equipment that could result in 

an increased demand for electricity most likely generated at power plants. In 

2005, California produced 78 percent of its own electricity with the remainder 

imported. The total amount generated in-state came from natural gas (37.7%), 

coal (20%), large hydro-electric (17%), nuclear (14.4%) and renewable energy 

sources (10.7%). In addition to increased electricity usage, some measures 

would require engine control devices that can reduce fuel efficiencies resulting in 

more fuel being used.

Reformulated Gasoline — Ethanol has about 30 percent less energy by volume 

than gasoline, therefore increased ethanol in gasoline will decrease fuel economy 

by about 0.3 percent for each 1 percent of ethanol. Staff is investigating a 

change in the procedure for certifying alternate formulations of reformulated 

gasoline that will lead to an increase in the use of ethanol.

Cold Ironing (Shore-side Power) — This process allows ships to run heating, 

air conditioning, lights and other operations by plugging into shore-side electrical 

power. This reduces emissions by allowing ships to shut down the uncontrolled 

auxiliary engines which traditionally have powered these electric-based activities. 

This technology can significantly reduce emissions from ship engines, however, 

the trade off is an incremental increase in energy demand. 
May 7, 2007 Appendix E 21 

Electrification of Equipment — Electric forklifts, dockside electrical hookups for 

larger marine vessels, and other strategies may increase electricity demand from 

power plants. The increase in power production will have an incidental increase 

in emissions (primarily NOx) from power plants. Air district permitting programs 

are in place to limit these emission increases. Overall, emissions should 

decrease significantly as fuels such as diesel and propane are replaced by the 

much cleaner natural gas burned at power plants as well as including more 

renewable energy sources to the power mix. 

Diesel Fueled Engines — Proposed measures to reduce emissions from dieselfueled engines could require the use of new diesel engines, engine modifications, 

alternatively fueled engines, add-on control devices such as particulate filters and 

catalysts, low sulfur diesel fuel, alternative fuel formulations, or other strategies. 

These strategies have the potential to cause a small decrease in fuel economy. 

Fuel economy impacts may be mitigated as engine design improves and engines 

operate more efficiently. 

Diesel Particulate Filters — A number of measures in the State Strategy would 

require the use of diesel particulate filters. These particulate filters must be 

periodically regenerated by burning off the accumulated carbon and associated 

hydrocarbons trapped on the filter. Active regeneration methods use external 

fuel or energy to heat the filter and regenerate it. 

Low Sulfur Diesel Fuel — Low sulfur diesel fuel requires increased 

hydrotreating of crude oil to remove sulfur, which would require additional energy 

consumption. 

VII. Geology/Soils 

Cumulative Impact: The State Strategy is not expected to cause any adverse 

impacts on geology or soils. 

VIII. Hazards and Hazardous Materials 

Cumulative Impact: The purpose of the State Strategy is to help California attain 

the federal 8-hour ozone and PM2.5 standards. ARB’s goal is to ensure that all 

individuals in California, especially children and the elderly, can live, work, and 

play in a healthy environment. Each of the measures in the State Strategy is 

intended to reduce the health risks from air pollution. The measures would 

reduce the pollutants that contribute to adverse health impacts, including: ozone, 

inhalable particles (including soot and dust), carbon monoxide, and toxic 

emissions (like particles emitted from diesel engines and benzene). There is a 

less than significant cumulative impact that would result from proposed 

measures. 
May 7, 2007 Appendix E 22 

Several State and federal agencies currently regulate hazardous and hazardous 

materials. A discussion of these regulations will follow State Strategy potential 

impacts. 

Consumer Products — In meeting lower VOC limits, there is a slight potential 

that products may become more flammable if reformulation increases the use of 

highly flammable, exempt VOC solvents such as acetone and methyl acetate. 

This could be of concern in the manufacture, storage, shipping and end use of 

the reformulated products. In many instances, however, manufacturers can use 

other, less flammable, exempt solvents and/or water borne formulations. It 

should be noted that the VOCs that acetone often replaces are generally highly 

flammable as well. In addition, acetone is currently used in many consumer 

products without significant safety concerns. Further, the U.S. Department of 

Transportation requires that consumer products meet specific criteria to ensure 

that there are no significant safety concerns with transport and storage of the 

products. 

Selective Catalytic Reduction (SCR) — Selective catalytic reduction is likely to 

be used on heavy-duty diesel engines to reduce NOx in the exhaust. Urea is the 

preferred reductant used to react with the NOx, in the presence of a catalyst, to 

form nitrogen gas and water. The use of ammonia as a reductant in motor 

vehicle-based SCR systems is very unlikely. 

Fuel Additives and Reformulation — Before proposing rules requiring fuel 

reformulations, staff must conduct a multimedia evaluation as required under 

California Health and Safety Code Section 43830.8. This evaluation will assess 

the potential impact associated with any fuel reformulation to the environment 

and public health including worker exposure. 

Diesel Particulate Filters — A number of measures in the State Strategy would 

require the use of diesel particulate filters. Some safety concerns include 

reduced visibility from the driver’s seat due to new equipment mounted near eye 

level, particularly on off-road equipment such as bulldozers, backhoes, and 

tractors. ARB staff believes that proper engineering design can mitigate or 

eliminate these potential problems. 

Diesel particulate filters must be regenerated by burning off the accumulated 

carbon and associated hydrocarbons trapped on the filter. Active regeneration 

methods use external fuel or energy to heat the filter and regenerate it. A slight 

potential exists for a runaway regeneration that could pose a fire hazard. Proper 

engineering design should mitigate or eliminate these potential risks. Diesel 

particulate filter measures will be written to assure that the design is proven 

effective. 
May 7, 2007 Appendix E 23 

Idling Inspections — Increased idling at inspection stops for heavy-duty diesel 

will expose people involved with or performing the inspections to toxic diesel PM 

emissions. Diesel engines emit a complex mix of pollutants, the most visible of 

which are very small carbon particles, or ‘soot’ known as diesel PM. 

Power Plants — Increased energy required from power plants may be a source 

of localized releases of toxic air contaminants causing exposure to workers and 

nearby residents. 

Hazardous Materials 

Hazards are related to the risks of fire, explosions, or releases of hazardous 

substances in the event of accident or upset conditions. Hazards are thus 

related to the production, use, storage, and transport of hazardous materials. 

Industrial production and processing facilities are potential sites for hazardous 

materials. Examples of hazardous materials used by consumers include fuels, 

paints, paint thinner, nail polish, and solvents. Hazardous materials may be 

stored at facilities producing such materials and at facilities where hazardous 

materials are part of the production processes. Storage refers to the bulk 

handling of hazardous materials before and after they are transported to the 

general geographical area of use. Currently, hazardous materials are 

transported throughout California via all modes of transportation including rail, 

highway, water, air, and pipeline. 

State law requires detailed planning to ensure that hazardous materials are 

properly handled, used, stored, and disposed of to prevent or mitigate injury to 

health or the environment in the event that such materials are accidentally 

released. The Office of Emergency Services (OES) enforces these 

requirements. Federal laws, such as the Emergency Planning and CommunityRight-to-Know Act of 1986 (also known as Title III of the Superfund Amendments 

and Reauthorization Act or SARA) impose similar requirements. 

The U.S. Department of Transportation (U.S. DOT) has regulatory responsibility 

for the safe transport of hazardous materials between states and to foreign 

countries. U.S. DOT regulations govern all means of transportation, except for 

those packages shipped by mail. Hazardous materials sent by U.S. mail are 

covered by U.S. Postal Service (USPS) regulations. Common carriers are 

licensed by the California Highway Patrol (CHP), pursuant to the California 

Vehicle Code, §32000. This section requires licensing of every motor (common) 

carrier who transports, for a fee, in excess of 500 pounds of hazardous materials 

at one time and every carrier, if not for hire, who carries more than 1,000 pounds 

of hazardous material of the type requiring placards. 

The CHP and Caltrans have primary responsibility for enforcing federal and State 

regulations and responding to hazardous materials transportation emergencies. 

The CHP enforces hazardous materials and hazardous waste labeling and 
May 7, 2007 Appendix E 24 

packaging regulations that prevent leakage and spills of material in transit and 

provide detailed information to cleanup crews in the event of an accident. 

Vehicle and equipment inspection, shipment preparation, container identification, 

and shipping documentation are all part of the responsibility of the CHP. The 

CHP also conducts regular inspections of licensed transporters to assure 

regulatory compliance. 

Pursuant to the Emergency Services Act, California has developed an 

Emergency Response Plan to coordinate emergency services provided by 

federal, State, and local government agencies and private persons. Response to 

hazardous materials incidents is one part of this plan. The plan is administered 

by OES, which coordinates the responses of other agencies including U.S. EPA, 

CHP, Department of Fish and Game, the applicable regional water quality control 

board, and local fire departments (see California Government Code, §8550). 

In addition, pursuant to the Hazardous Materials Release Response Plans and 

Inventory Law of 1985 (the Business Plan Law), local agencies are required to 

develop area plans for response to releases of hazardous materials and wastes. 

These emergency response plans depend to a large extent on the business 

plans submitted by persons who handle hazardous materials. An area plan must 

include pre-emergency planning of procedures for emergency response, 

notification and coordination of affected government agencies and responsible 

parties, training, and follow-up. Hazardous materials incidents are reported to 

OES, which compiles and archives the information. 

Public Health 

The Toxic Air Contaminant Identification and Control Act (Health and Safety 

Code §§ 39650 et seq., Food and Agriculture Code Sections 14021 et seq.) 

established California’s two-phased program to identify and control air toxics. In 

the first phase (risk assessment), ARB selects substances for review, 

considering criteria relating to “the risk of harm to public health, amount or 

potential amount of emissions, manner of, and exposure to, usage of the 

substance in California, persistence in the atmosphere, and ambient 

concentrations in the community” (Health and Safety Code § 39666(f)). One 

example of an identified TAC is particulate matter from diesel-fueled engines. 

In the risk management phase of the program, ARB reviews the emission 

sources of an identified TAC to determine if any regulatory action is necessary to 

reduce the risk. The analysis includes a review of controls already in place, the 

available technologies and associated costs for reducing emissions, and the 

associated risk. 

Also in the risk management phase, ARB, working closely with the air districts, is 

responsible for developing control measures for all identified TACs except those 

used as pesticides. Pesticides are evaluated in a similar process by the 
May 7, 2007 Appendix E 25 

Department of Pesticide Regulation. Following ARB adoption of measures to 

control a specific toxic compound, the districts must adopt equal or more 

stringent regulations for the stationary sources in their jurisdiction. Regulations 

to control airborne toxic emissions from mobile sources are the responsibility of 

ARB. 

The Air Toxics Hot Spots Program (Health and Safety Code §§ 44300-44384) 

requires facilities to report their toxic air emissions, ascertain health risks, and to 

notify nearby residents of significant risks. Facilities that pose a significant health 

risk to the community are required to reduce their risk through a risk 

management plan. 

 Worker Safety Requirements 

The California Occupational Safety and Health Administration (Cal/OSHA) and 

the Federal Occupational Safety and Health Administration (OSHA) are the 

agencies responsible for assuring worker safety in the handling and use of 

chemicals in the workplace. In California, Cal/OSHA assumes primary 

responsibility for developing and enforcing workplace safety regulations. Under 

the authority of the Occupational Safety and Health Act of 1970, OSHA has 

adopted numerous regulations pertaining to worker safety (contained in 29 CFR). 

These regulations set standards for safe workplaces and work practices, 

including the reporting of accidents and occupational injuries. Some OSHA 

regulations contain standards relating to hazardous materials handling, including 

workplace conditions, employee protection requirements, first aid, and fire 

protection, as well as material handling and storage. Because California has a 

federally-approved OSHA program, it is required to adopt regulations that are at 

least as stringent as those found in 29 CFR. 

Cal/OSHA regulations concerning the use of hazardous materials in the 

workplace (detailed in CCR, Title 8) include requirements for employee safety 

training, availability of safety equipment, accident and illness prevention 

programs, hazardous substance exposure warnings, and emergency action and 

fire prevention plan preparation. Cal/OSHA enforces hazard communication 

program regulations containing training and information requirements, including 

procedures for identifying and labeling hazardous substances. The hazard 

communication program also requires that Material Safety Data Sheets (MSDSs) 

be available to employees and that employee information and training programs 

be documented. These regulations also require preparation of emergency action 

plans (escape and evacuation procedures, rescue and medical duties, alarm 

systems, and emergency evacuation training). 

Both federal and State laws include special provisions for hazard communication 

to employees in research laboratories, including training in chemical work 

practices. The training must include instruction in methods for the safe handling 

of hazardous materials, an explanation of MSDSs, use of emergency response 
May 7, 2007 Appendix E 26 

equipment and supplies, and an explanation of the building emergency response 

plan and procedures. Chemical safety information must also be available at the 

workplace. More detailed training and monitoring is required for the use of 

carcinogens, ethylene oxide, lead, asbestos, and certain other chemicals listed in 

29 CFR. Emergency equipment and supplies, such as fire extinguishers, safety 

showers, and eye washes, must also be kept in accessible places. Compliance 

with these regulations reduces the risk of accidents and adverse worker health 

effects. 

The National Fire Code (NFC), Standard 45 (published by the National Fire 

Protection Association) contains standards for laboratories using chemicals that 

are not requirements but are generally employed by organizations in order to 

protect workers. These standards provide basic protection of life and property in 

laboratory work areas through prevention and control of fires and explosions, and 

also serve to protect personnel from exposure to non-fire health hazards. While 

NFC Standard 45 is regarded as a nationally recognized standard, the California 

Fire Code (24 CCR) contains State standards for the use and storage of 

hazardous materials and special standards for buildings where hazardous 

materials are found. Some of these regulations consist of amendments to NFC 

Standard 45. California Fire Code regulations require emergency pre-fire plans 

to include training programs in first aid, the use of fire equipment, and methods of 

evacuation. 

IX. Land Use/Planning 

Cumulative Impact: The State Strategy is not expected to cause any adverse 

impacts on land use and planning. 

X. Mineral Resources 

Cumulative Impact: The State Strategy is not expected to cause any adverse 

impacts on mineral resources. 

XI. Noise 

Cumulative Impact: The cumulative effect of the State Strategy will not have a 

potentially significant impact on noise, although an increase of the number of 

trucks idling at inspection stops may result in increased noise. 

Diesel-Fueled Engines — The recommended measures to reduce emissions 

from diesel-fueled engines could require the use of add-on control devices such 

as particulate filters, oxidation catalysts and engine modifications. This could 

result in a potential increase in noise levels due to exhaust system changes to 

accommodate add-on controls. However, testing of current add-on controls has 

shown no increase in noise, and ARB staff does not expect future adverse noise 

impacts. 
May 7, 2007 Appendix E 27 

XII. Population and Housing 

Cumulative Impact: The State Strategy is not expected to cause any adverse 

impacts on population and housing. 

XIII. Public Services 

Cumulative Impact: The State Strategy is not expected to cause any adverse 

impacts on public services. 

XIV. Recreation 

Cumulative Impact: The State Strategy is not expected to cause any adverse 

impacts on recreation. By reducing the number of days with unhealthy air 

quality, ARB expects that our parks and outdoor recreational facilities could see 

increased usage by children, the elderly, asthmatics, and others with sensitive 

airways or chronic breathing problems.

XV. Solid/Hazardous Waste 

Cumulative Impact: The cumulative impact of all strategies in the State Strategy 

would be a small, but potentially significant, increase of both solid and hazardous 

wastes. To mitigate these impacts, ARB will work with the California Department 

of Toxic Substances Control (DTSC) and the California Integrated Waste 

Management Board (CIWMB) to reduce waste production in these and other 

areas. 

State and local agencies currently regulate solid and hazardous waste. A 

discussion of these regulations will follow the proposed strategies below. 

Vehicle Retirement Program — High-mileage and older vehicles are likely 

candidates for scrappage rendering them inoperable to pollute. There are many 

non-hazardous materials in a vehicle that could be discarded in landfills. Such 

materials include iron and aluminum engine blocks, steel and plastic from 

chasses and interiors, glass, chromium-containing bumpers, and rubber hoses. 

Mitigation for the expansion of this program would involve reusing or recycling 

the above mentioned materials. According to the Bureau of Automotive Repair, 

on average 90 percent of a scrapped vehicle is recycled with the remaining 10 

percent considered fluff which is typically landfilled. A significant amount of scrap 

and recycled materials are shipped to foreign markets. 

Diesel-Fueled Engines and Vehicles — The proposed measures to reduce 

emissions from diesel-fueled engines and vehicles could require the use of new 

diesel engines or add-on control devices such as particulate filters and oxidation 

catalysts. Potential adverse impacts include increased scrapping of diesel 

engines and vehicles, and impacts due to handling and disposal of collected 
May 7, 2007 Appendix E 28 

particulate matter. Also, diesel oxidation catalysts are considered hazardous at 

the end of life. The impact of accelerated vehicle scrapping can be largely 

mitigated by recycling and reclamation of hazardous materials. 

Diesel Particulate Filters — A number of measures in the State Strategy would 

require use of diesel particulate filters. Diesel particulate filters will probably 

produce a small amount of waste ash for disposal. This waste is estimated at 

about 10 to 150 grams of ash per vehicle per year and is projected to be 

considered a hazardous material due to zinc content. While most larger 

maintenance facilities can be expected to handle, collect, and dispose of this 

material properly, it is less certain how smaller facilities will handle waste ash. 

The filters themselves will eventually also be retired. Some filters contain a 

precious metal catalyst that is valuable for recycling and reclaiming. Other spent 

filters may not be worth recycling and may be disposed of at a proper landfill. 

We do not expect that the spent filters themselves will be considered a 

hazardous material. 

Electrification of Equipment — Electrification equipment can provide significant 

reductions of air pollutant emissions. However, electrification strategies may 

result in the production and use of a significant number of batteries. These 

batteries are normally recycled, and the recycle rate for lead-acid batteries is 

currently more than 95 percent. However, the increase in the number of spent 

batteries to be processed would potentially have significant impacts on the 

recycling industry and on the disposal system for non-recyclable materials. 

Leasing, deposit, or rebate programs for electric batteries could be required to 

increase recycling. A spent battery exchange for battery replacement could also 

reduce waste impacts. With these mitigation measures in place, battery disposal 

impacts should not be significant. 

 Solid Waste Regulations 

Solid waste consists of residential wastes (garbage and rubbish produced by 

households), construction wastes, commercial and industrial wastes, home 

appliances and abandoned vehicles, and sludge residues (waste remaining at 

the end of the sewage treatment process). CCR Title 14, Division 7, provides the 

State standards for the management of facilities that handle and/or dispose of 

solid waste. CCR Title 14, Division 7, is administered by the CIWMB and the 

designated Local Enforcement Agency (LEA). The designated LEA for each 

county is the County Department of Environmental Health. 

CCR Title 14, Division 7, establishes general standards to provide required levels 

of performance for facilities that handle and/or dispose of solid waste. Other 

Title 14 requirements include operational plans, closure plans, and post-closure 

monitoring and maintenance plans. Title 14 covers various solid waste facilities 

including, but not limited to landfills, material recovery facilities (MRF), transfer 

stations, and composting facilities. 
May 7, 2007 Appendix E 29 

 Hazardous Waste Regulations 

Hazardous materials are substances with certain physical properties that could 

pose a substantial present or future hazard to human health or the environment 

when improperly handled, disposed, or otherwise managed. As defined in 

CCR Title 22, Division 4.5, Chapter 11, Article 3, hazardous materials are 

grouped into the following four categories based on their properties: toxic 

(causes human health effects), ignitable (has the ability to burn), corrosive 

(causes severe burns or damage to materials) and reactive (causes explosions 

or generates toxic gases). A hazardous waste is any hazardous material that is 

discarded, abandoned, or otherwise is not recycled. If improperly handled, 

hazardous materials and wastes can result in public health hazards if released to 

the soil or groundwater or through airborne releases in vapors, fumes, or dust. 

Under the Resource Conservation and Recovery Act (RCRA), U.S. EPA 

regulates the generation, transportation, treatment, storage, and disposal of 

hazardous waste. RCRA was amended in 1984 by the Hazardous and Solid 

Waste Act (HSWA), which affirmed and extended the concept of regulating 

hazardous wastes from generation through disposal. HSWA specifically prohibits 

the use of certain techniques for the disposal of some types of hazardous 

wastes. Under RCRA, individual states may implement their own hazardous 

waste programs in lieu of RCRA as long as the state program is at least as 

stringent as the federal RCRA requirements. U.S. EPA approved California’s 

program to implement federal regulations as of August 1, 1992. 

DTSC administers the Hazardous Waste Control Law (HWCL). Under HWCL, 

DTSC has adopted extensive regulations governing the generation, 

transportation, and disposal of hazardous wastes. HWCL differs little from 

RCRA; both laws impose “cradle to grave” regulatory systems for handling 

hazardous wastes in a manner that protects human health and the environment. 

Regulations implementing HWCL are generally more stringent than regulations 

implementing RCRA. HWCL regulations list more than 780 hazardous 

chemicals, as well as nearly 30 more common materials that may be hazardous, 

and establish criteria for identifying, packaging, and labeling hazardous wastes. 

They prescribe management practices for hazardous wastes; establish permit 

requirements for hazardous waste treatment, storage, disposal, and 

transportation; and identify hazardous wastes that cannot be disposed of in 

landfills. 

Under both RCRA and HWCL, hazardous waste manifests must be retained by 

the generator for a minimum of three years. Hazardous waste manifests list a 

description of the waste, its intended destination, and regulatory information 

about the waste. A copy of each manifest must be filed with DTSC. The 

generator must match copies of hazardous waste manifests with certification 

notices from the treatment, disposal, or recycling facility. Hazardous waste as 
May 7, 2007 Appendix E 30 

defined in the Code of Federal Regulations Title 40 (40 CFR) 261.20 and 

CCR Title 22, Article 9 (including listed substances, 40 CFR 261.30) is disposed 

of in Class I landfills. California has enacted strict legislation for regulating 

Class I landfills (Health and Safety Code, §§25209 - 25209.7). For example, the 

treatment zone of a Class I landfill must not extend more than five feet below the 

initial surface and the base of the zone must be a minimum of five feet above the 

highest anticipated elevation of underlying groundwater (Health and Safety 

Code, §25209.1(h)). The Health and Safety Code also requires Class I landfills 

to be equipped with liners, a leachate collection and removal system, and a 

groundwater monitoring system (Health and Safety Code, §25209.2(a)). Such 

systems must meet the requirements of DTSC and the SWRCB (Health and 

Safety Code, §25209.5). 

XVI. Transportation and Traffic 

Cumulative Impact: Modernization of motor vehicle fleets has the potential to 

generate increased travel. Because newer vehicles tend to be driven more 

frequently and make longer trips, this could increase the number of vehicles on 

the roads. Although modernization and turnover of fleets is intended to decrease 

the emissions from these vehicles, more vehicles on the roads could result in 

increased congestion. 

XVII. Water Resources 

Cumulative Impact: The State Strategy would significantly reduce a number of 

air pollutants and the reductions in deposition will improve overall water quality in 

California. Also, accelerated retirement of older equipment with potentially leaky 

gasoline or diesel engines will reduce fluid (oil and grease) drips, resulting in 

cleaner storm water runoff. Several potentially significant adverse water quality 

impacts are identified, including impacts from reformulated gasoline and 

reformulated low-VOC consumer products. 

Although rain can effectively scrub the air clean, air pollutants absorbed by 

rainwater can have an adverse impact when deposited into surface waters. NOx 

and SOx emissions can form acids that can lower the pH of sensitive mountain 

lakes and streams and adversely affect the flora and fauna. NOx emissions can 

oxidize to nitrate, a powerful fertilizer, and can spur algae growth contributing to 

lake water turbidity and algae blooms. Organic molecules can be deposited in 

surface waters and affect the aquatic plants and animals. Toxic air contaminants 

(TACs) can dissolve in rain and eventually stress or kill organisms. 

This environmental analysis of water resources is divided into two major 

categories—water quality and water demand. However, no significant negative 

impacts on water demand were identified. Several State and federal agencies 

regulate water resources and water quality. A discussion of these agencies’ 

regulations will follow the State Strategy potential impacts. 
May 7, 2007 Appendix E 31 

Reformulated Gasoline — Ethanol in Gasoline 

Since the phase out of MTBE from California gasoline formulations and federal 

denial of a request for a waiver from the oxygenate requirement, California has 

reformulated its gasoline with ethanol. As modifications to the rule are 

developed, there may be an increase of the amount of ethanol used as an 

oxygenate. There is potential for biological effects from this formulation in the 

event there is discharge to groundwater or surface waters. Ethanol may have an 

impact on the biodegradation of hydrocarbons which can worsen the effects of a 

gasoline spill. Ethanol may inhibit biological degradation of Benzene, Toluene, 

EthylBenzene and Xylene (BTEX) due to bacterial preference for ethanol 

resulting in longer groundwater plumes of BTEX. 

Diesel-Fueled Engines — The State Strategy to reduce emissions from onroad, off-road, and stationary diesel-fueled engines could require or encourage 

the use of alternatively fueled engines and alternative fuel formulations. Because 

some alternative diesel fuel formulations and additives could more readily 

dissolve in water, these control measures have the potential to adversely impact 

local ground and surface waters. 

The use of these alternative fuels is not expected to result in significantly greater 

adverse water quality impacts than the use of regular diesel fuels. A number of 

rules and regulations are currently in place to minimize the potential impacts from 

underground leaking storage tanks and spills from fueling activities. These 

include requirements for the construction of the storage tanks, requirements for 

double containment, and installation of leak detection systems. These 

regulations minimize the potential for additional leaks from the use of diesel fuels 

or alternative fuels. 

Consumer Products — Two toxic air contaminants (TAC) used in some 

consumer products, methylene chloride (MeCl) and perchloroethylene (Perc), are 

specifically exempted from the VOC definition in recognition of their very low 

ozone-forming capabilities. Some manufacturers could use MeCl or Perc in their 

formulations to reduce the VOC content to meet future limits, creating potential 

adverse environmental impacts for primarily air, and possibly, though much less 

likely, soil and water. 

ARB staff has recognized the potential for increased use of TACs in consumer 

products and has taken steps to mitigate and limit the use of these compounds in 

recent Board actions. These actions include: the toxics control measure for 

automotive maintenance and repair activities; aerosol adhesives limits in the 

consumer products regulation; the prohibition of para-dichlorobenzene in solid air 

fresheners and toilet/urinal care products; and reactivity limits in the aerosol 

coating regulations. ARB periodically surveys all categories for their chemical 

composition including TACs and also tracks the use of MeCl and Perc in 

regulated consumer products through yearly manufacturer reporting 

requirements. Further, ARB staff has proposed VOC limits in the past that were 
May 7, 2007 Appendix E 32 

achievable without the increased use of TACs. Furthermore, Proposition 65 

labeling requirements discourage manufacturers from reformulating consumer 

products with TACs. 

ARB staff actively seeks to prevent increased use of TACs when setting new 

VOC limits. In the future, if new products contain Perc and MeCl, ARB staff will 

monitor their use and limit or prohibit their use in additional consumer products, 

when applicable. Mitigation measures will be implemented if a significant 

presence of consumer product-related Perc is anticipated in wastewater. 

Vehicle Retirement Program — High-mileage and older vehicles are likely 

candidates for scrappage. Their deterioration leads to increased emissions. 

Once scrapped, they can no longer pollute. Scrapped vehicles commonly 

contain residual fuels, such as gasoline, lubricating oils and other fluids that may 

potentially harm water quality if not properly handled. There are regulations and 

rules to properly manage these programs, however, there is a potential for 

adverse environmental impacts if these pollutants are leaked to surface and 

groundwater. 

 State and Regional Water Boards 

California has an extensive regulatory program to control water pollution. The 

most important statute governing water quality is the Porter-Cologne Act, which 

gives the State Water Resources Control Board (SWRCB) and the nine regional 

water quality control boards (RWQCB) broad powers to protect surface and 

groundwater supplies in California, regulate waste disposal, and require cleanup 

of hazardous conditions (California Water Code §§3000-13999.16). In particular, 

the SWRCB establishes water-related policies and approves water quality control 

plans, which are implemented and enforced by the RWQCBs. The nine regional 

boards include: North Coast, San Francisco Bay, Central Coast, Los Angeles, 

Central Valley, Lahontan, Colorado River Basin, Santa Ana, and San Diego. 

It is the responsibility of each regional board to prepare water quality control 

plans to protect surface and groundwater supplies within its region. These plans 

must: identify important regional water resources and their beneficial uses, such 

as domestic, navigational, agricultural, industrial, and recreational; establish 

water quality objectives, limits, or levels of water constituents or characteristics 

established for beneficial uses and to prevent nuisances; and present an 

implementation program necessary to achieve those water quality objectives. 

These plans also contain technical information for determining waste water 

discharge requirements and taking enforcement actions. The plans are typically 

reviewed and updated every three years (California Water Code §13241). 

California dischargers of waste that “could affect the quality of the waters of the 

State” are required to file a report of waste discharge with the appropriate 

regional water board (California Water Code §13260). The report is essentially a 
May 7, 2007 Appendix E 33 

permit application and must contain information required by the regional board. 

After receipt of a discharge report, the regional board will issue “waste discharge 

requirements” analogous to a permit with conditions prescribing the allowable 

nature of the proposed discharge (California Water Code §§3263, 13377, and 

13378). 

National Pollutant Discharge Elimination System Requirements 

Most discharges into California’s waters are regulated by the National Pollutant 

Discharge Elimination System (NPDES), a regulatory program under the federal 

Clean Water Act. The NPDES is supervised by U.S. EPA, but administered by 

the SWRCB. NPDES requirements apply to discharges of pollutants into 

navigable waters from a point source, discharges of dredged or fill material into 

navigable waters, and the disposal of sewage sludge that could result in 

pollutants entering navigable waters. California has received U.S. EPA approval 

of its NPDES program. Pursuant to California’s NPDES program, any waste 

discharger subject to the NPDES program must obtain an NPDES permit from 

the appropriate RWQCB. The permits typically include criteria and water quality 

objectives for a wide range of constituents. The NPDES program is selfmonitoring, requiring periodic effluent sampling. Permit compliance is assessed 

monthly by the local RWQCB. Any NPDES violations are then categorized and 

reported to U.S. EPA on a quarterly basis. 

U.S. EPA has also published regulations that require certain industries, cities and 

counties to obtain NPDES permits for stormwater discharges [55 CFR (1990)]. 

The regulations set permit application requirements for classes of stormwater 

discharges specifically identified in the federal Clean Water Act. The regulated 

stormwater discharges include those associated with industrial activity and from 

municipal storm sewer systems serving a population of 100,000 or more. 

Discharges to Publicly-Owned Treatment Works (POTWs)

Water discharges to a public sewage system (referred to generically as a 

POTW), rather than directly to the environment, are not subject to the NPDES 

discharge requirements. Instead, such discharges are subject to federal 

pretreatment requirements under §§307(b) and (c) of the Clean Water Act 

[33 USC §1317(b)-(c)]. Although these pretreatment standards are enforced 

directly by U.S. EPA, they are implemented by local sanitation districts (Monahan 

et al., 1993). The discharger, however, has the responsibility to ensure that the 

waste stream complies with the pretreatment requirements of the local system. 

Any facility using air pollution control equipment affecting water quality must 

receive a permit to operate from the local sanitation district. In cases where 

facilities modify their equipment or install air pollution controls that generate or 

alter existing wastewater streams, owner/operators must notify the local 

sanitation district and request that their existing permit be reviewed and modified. 
May 7, 2007 Appendix E 34 

To ensure compliance with wastewater pretreatment regulations, local sanitation 

districts sample and analyze the wastewater streams from facilities 

approximately two to four times per year. Persons who violate California’s water 

quality laws are subject to a wide array of enforcement provisions. In 1990, 

U.S. EPA revised and extended existing regulations to further regulate 

hazardous waste dischargers and require effluent testing by POTWs. To comply 

with revised permit limits, POTWs may alter their operations or impose more 

stringent local limits on industrial user discharges of hazardous wastes (Monahan 

et al., 1993). POTWs in California are operated by sanitation districts that adopt 

ordinances establishing permit systems and fee structures. 

Department of Pesticide Regulation’s 2008 Pesticide Element

The pesticide element requires the Department of Pesticide Regulation (DPR) to 

implement regulations that restrict the amount of VOCs that may be emitted from 

field fumigation. The 2008 element updates the current pesticide element of the 

ozone SIP, which provides for percentage reductions in emissions from 1990 

levels. 

An analysis of potentially significant environmental effects will occur before final 

implementation of the specific field fumigant regulations. The fumigant 

regulations have been developed enough to assess the potential environmental 

impacts at this point. 

Cumulative Impact of 2008 Pesticide Element: Adoption of this element into 

the SIP would not have significant or potentially significant adverse effects on the 

environment. 

Potential Environmental Impacts of 2008 Fumigant Regulations 

The fumigant regulations to be implemented in 2008 will establish limits on the 

amount of VOCs that may be emitted from field fumigation in certain areas and 

will prescribe allowable application methods statewide. Pesticide applicators are 

expected to take one or more of the following actions to comply with the 

regulations: Use lower emission application methods, reduce application rates, 

reduce the acres fumigated, and shift fumigant applications outside the peak 

ozone season. DPR expects most of the required emission reductions to come 

through use of lower emission application methods, generally tarping, postfumigation water treatments, and drip chemigation. The regulations will give 

applicators a choice of application methods, but in general the impacts will be 

negligible regardless of which options are selected. 

DPR's review of the proposed action showed that no significant adverse 

environmental impact to California's environment can reasonably be expected to 

occur from implementing its commitment to promulgate fumigation regulations. 
May 7, 2007 Appendix E 35 

In reaching this conclusion, DPR considered the possible impacts discussed 

below. 

Air Quality 

Shifting fumigations outside the peak ozone season could cause current 

particulate emissions from tractors and other application equipment to shift from 

summer to late fall or early spring. However, increased fumigations and 

associated particulate emissions during the winter peak particulate season are 

unlikely due to wet fields and other constraints. 

Since the 2008 fumigant regulation would establish application limits during May 

through October only, there is a potential for an increased use of fumigants in the 

months preceding or following the peak ozone season. However, current DPR 

regulations and U.S. EPA label restrictions are designed to prevent acute or 

chronic toxic exposure and are sufficient to avoid any adverse effects of toxic 

emissions from any increased use of fumigants. 

In addition, the restriction of allowable application methods in the proposed 

regulations will reduce air emissions of the fumigants. Emissions of fumigants 

included in the proposed regulation have little or no contribution to particulate 

matter pollution, acid rain, climate change, or other air quality impacts. 

Agricultural Resources

Reducing the acreage fumigated would cause the previously fumigated fields to 

be converted to crops that do not use fumigants or to non-agricultural uses. The 

most likely conversions in specific areas are unknown at this time. DPR expects 

that growers in all areas can, and will, meet the emission limits primarily through 

changing application methods, and thus the regulations will not cause a 

significant reduction in the number of acres fumigated or conversion of 

agricultural land to other uses. 

Resource/Energy Use

Post-fumigation water treatments and drip chemigation (pesticide application via 

an irrigation system rather than by tractor application) will require greater 

quantities of water, with associated energy use and other effects. Less diesel 

fuel and other desirable effects associated with decreased tractor use will offset 

any potential impacts. However, the relative increase from current water use is 

expected to be negligible. 

Solid Waste

The disposal of solid waste may increase slightly due to use of plastic tarpaulins 

under the proposed regulations, but the increase is not expected to be significant 
May 7, 2007 Appendix E 36 

since a great majority of the fumigations already use tarpaulins when it is a 

feasible mitigation measure. 

Water Quality

DPR’s evaluation of the post-fumigation water treatments and drip chemigation 

applications show virtually no potential for ground water contamination by the 

fumigants with the estimated irrigation increases. 

Other

Fumigation is primarily used to control diseases and nematodes. If fumigant 

application rates are reduced as a result of the regulations, use of non-fumigant 

pesticides, such as fungicides and nematicides could be increased. Increasing 

the use of such non-fumigant pesticides may result in potential adverse 

environmental impacts to soil, air or water. 

Environmental Analysis for the Proposed Revision to the Pesticide 

Commitment in the 1994 Ozone SIP 

Aside from the Ventura area, the 2008 pesticide element requires the same or 

more VOC reductions than the current pesticide element (1994 Plan). The 2008 

pesticide element does, however, allow less VOC reductions for pesticide use in 

the Ventura area only. Either plan would provide for significant reductions from 

actual, current levels. For Ventura County to meet the targets of the 1994 Plan, 

2.2 tons per day reductions are required. The 2008 pesticide element would 

require a 1.2 ton per day reduction that would result from the 2008 fumigation 

regulations. The additional ton of VOC reductions needed to satisfy the 1994 

SIP commitment will instead come from other sources of VOCs in the Ventura 

area. A more detailed discussion of this allowance and emission reduction 

offsets is included in the Appendix H. 

Potential environmental impacts resulting from the proposed revision to the 1994 

Plan may come from the use of methyl bromide and methyl isothiocyanategenerating fumigants. These fumigants comprise approximately 50 percent of 

the pesticide VOC inventory in Ventura. These two fumigants have very low 

reactivity, indicating that they do not appreciably contribute to ozone formation. 

Methyl bromide is an ozone depleting substance, and its production and 

importation are regulated under the Clean Air Act. Ozone depletion is not a 

localized effect, and the amount of methyl bromide emitted due to this Plan is 

negligible. It is estimated that 0.5 tons per day more methyl bromide will be 

emitted from field fumigation under the 2008 pesticide element target than would 

be allowed under the 1994 Plan. This is approximately 0.0002 percent of the 

worldwide methyl bromide emissions. No other adverse effects should occur 

because the fumigants included in the proposed regulation have little or no 
May 7, 2007 Appendix E 37 

contribution to particulate matter pollution, acid rain, climate change, or other air 

quality impacts. 

DPR regulations and U.S. EPA label restrictions currently in place are designed 

to prevent acute or chronic toxic exposure. They are sufficient to avoid adverse 

effects of toxic emissions from any additional use of these fumigants that would 

result if the VOC reduction targets in the pesticide element of the SIP were one 

ton per day higher in Ventura in 2008. 

Cumulative Impact of Proposed Revision to the 1994 Plan: The change to 

the 2008 pesticide element targets will not have a significant adverse 

environmental impact on air quality.

Cumulative Impacts of State Measures and Local District Measures 

The cumulative impacts of the State Strategy within each impact area have been 

discussed in the previous sections. This analysis does not set forth the 

environmental impacts of measures contained in district plans, as districts are 

required to perform their own environmental analysis of their stationary source 

control measures. The 8-hour Ozone and PM2.5 SIP, however, will incorporate 

both state and local measures. Local measures from the non-attainment areas 

may also have adverse environmental impacts. Interested parties that want to 

review and assess impacts associated with each district should do so at the 

district level. ARB, as the state agency responsible for preparing the SIP, 

coordinating district efforts to comply with federal SIP requirements and 

forwarding the SIP components to U.S. EPA, will collect and compile the each 

district’s plan, along with their environmental documentation, and send the entire 

SIP package to U.S. EPA. 

At this time, the air districts with the most serious air quality problems in the 

State, South Coast Air Basin and the San Joaquin Valley, both have performed 

environmental analyses for their plans. All other non-attainment districts are 

expected to perform environmental analyses prior to adoption by their respective 

district boards. 

The cumulative impacts discussion contained in the South Coast Air Quality 

Management District’s Draft Environmental Impact Report (EIR) for the 2007 Air 

Quality Management Plan, is hereby incorporated by reference. The San 

Joaquin Valley Unified Air Pollution Control District Initial Study/Proposed 

Negative Declaration is also hereby incorporated by reference. 
May 7, 2007 Appendix E 38 

Project Alternatives

As discussed at the beginning of this appendix, ARB meets the criteria for a 

Certified State Regulatory Program. This certification requires ARB to present a 

range of reasonable alternatives for any project under consideration. CEQA 

requires a certified agency to include one of the following in the document: 

1) Alternatives to the activity and mitigation measures to avoid or reduce any 

significant or potentially significant effects that the project might have on the 

environment; or 2) A statement that the agency’s review of the project showed 

that the project would not have any significant or potentially significant effects on 

the environment, and therefore no alternatives or mitigation measures are 

proposed to avoid or reduce any significant effects on the environment. The 

statement shall be supported by a checklist or other documentation to show the 

possible effects that the agency examined in reaching this conclusion. (CEQA 

Guidelines Section 15252). 

The alternatives presented in this appendix were evaluated for their comparative 

merits to the proposed project. Under CEQA, the alternatives are required to 

feasibly obtain the objectives of the proposed project. For this reason, it is 

important to note the State of California is under legal obligation to prepare a 

State Implementation Plan which demonstrates it will reach attainment for the 

8-hour ozone and PM2.5 standards. 

Review of the cumulative impacts from all proposed new measures or strategies 

shows there may be potentially significant adverse impacts if all measures are 

adopted. Therefore, alternatives to the State Strategy are considered below. 

Alternative 1 — No Project 

CEQA documents typically assume that the adoption of a ‘no project’ alternative 

would result in no further action on the part of the project proponent or lead 

agency. For example, in the case of a proposed housing development project, 

adopting the ‘no project’ alternative terminates further consideration of that 

housing development or any housing development alternative identified in the 

associated CEQA document. In that case, the existing setting would remain 

unchanged. 

One interpretation of the ‘no project’ alternative is that if this alternative was 

selected, all the measures in the State Strategy are rejected. Since the State 

Strategy contains all currently known feasible State strategies or measures that 

ARB could potentially take to reduce ozone-forming emissions, this would mean 

that no additional measures on existing sources or measures on uncontrolled 

sources would be developed. The result would be the eventual deterioration of 

California air quality as population increases and would very likely prevent the 

State from being able to meet its requirement to meet the 8-hour ozone and 

PM2.5 standards. In addition, California would fail to meet federal Clean Air Act 
May 7, 2007 Appendix E 39 

mandates and would be subject to federal sanctions. Water quality would suffer 

as acidic rain increases and toxic air contaminants are deposited on the ground. 

Public exposure to toxic materials would increase. Higher levels of air pollutants 

would deteriorate aesthetics by increasing haze and would damage crops. Only 

modest benefits would be achieved from a no project alternatives, such as any 

small increase in solid or hazardous waste would not be generated. 

 Alternative 2 — Adopt Fewer Measures 

As mentioned previously, the State Strategy contains all measures to reduce 

ozone that ARB staff has determined are feasible to achieve. Instead of adopting 

all of these measures, ARB could adopt only some of them, although there would 

be numerous alternative subsets of the measures identified in the State Strategy 

to consider. However, adopting fewer measures would not result in the expected 

emissions reductions needed to meet the 8-hour ozone and PM2.5 standards. 

This would then place an increased responsibility on local districts and the 

federal government to achieve sufficient emissions reductions to meet the 

standard. 

Alternative 3 — Adopt Measures with Different Emission Standards 

For each individual measure, many alternatives exist for various levels of control 

and variable emission standards for the regulated sources. It is not possible to 

examine these many alternatives in detail without engaging in speculation, 

because the measures ultimately adopted by ARB will depend on the information 

that is learned in the future during the regulatory development process. In 

general, however, ARB staff believes that it will be necessary to adopt all State 

Strategy measures and emission standards that are determined to be feasible, 

rather than a subset of feasible measures and standards. To attain the federal 

ozone standard in the South Coast and San Joaquin Valley, significant additional 

emission reductions will be needed beyond the defined measures specifically 

identified in the Strategy. Therefore, failing to adopt all feasible measures and 

emission standards would result in failure to meet federal Clean Air Act 

mandates and would subject the State to federal sanctions. 

Impacts of Individual Proposed Measures

The measures in the State Strategy will help make progress toward our goal of 

healthy air for all Californians. Each of the defined State measures was 

evaluated to identify adverse environmental impacts. The following table lists 

each of the measures, any potentially significant environmental impacts, and 

possible mitigation strategies
May 7, 2007 Appendix E 40 

Potential Adverse Environmental Impacts of 

the Proposed 2007 State Strategies for the California SIP 

Strategy Description Potential Adverse Environmental Impacts Pote

PASSENGER VEHICLES Expanded Passenger Vehicle Retirement: 

Increase the number of vehicles in the BAR scrappage program. 

Air: Potential for incidental refrigerant leaks from 

air conditioning systems when attaching equipment to facilitate removal of the refrigerant. Solid/Hazardous Waste: Lead, chromium, and 

mercury in vehicles can become toxic air contaminants and pose health risks to facility workers. Solid/Hazardous Waste: Increased scrappage including steel, plastics and other materials that could potentially be disposed in landfills. Water: Fuel, oil, and lubricants may leak and 

disperse into groundwater. If improperly disposed, elements including lead, chromium and mercury can disperse into ground or surface water as part of landfill leachate. 

Ensure bepractices aPromote rof hazardoPromote rparts and Proper facadherence the collect

Modification of Reformulated Gasoline Program: 

Modify California’s Reformulated Gasoline Program to offset ROG emissions due to the increased use of ethanol as an additive. 

Energy: Ethanol blends have about 30 percent 

less energy by volume than gasoline, so increased ethanol in gasoline will decrease fuel economy by about 0.3 percent for each 1 percent of ethanol. 

Manufactuuse more new motor increased older modenot be add
May 7, 2007 Appendix E 41 

Potential Adverse Environmental Impacts of 

the Proposed 2007 State Strategies for the California SIP 

Strategy Description Potential Adverse Environmental Impacts Pote

Water: Ethanol reduces electron-acceptors in 

groundwater and reduces biodegradation of benzene, toluene, ethylbenzene, and xylene contained in gasoline. Potential for increase of groundwater plumes. 

None iden

Smog Check Improvements

Low Pressure Evaporative Test: 

Require testing and repair of evaporative system leaks for all vehicles subject to Smog Check inspection. 

Solid/Hazardous Waste: Increased disposal of 

faulty emission control parts. 

Recycle fucatalyst w

More Stringent Cutpoints: 

Set more stringent Smog Check pass/fail cutpoints. 

Solid/Hazardous Waste: Increased disposal of 

faulty emission control parts. 

Recycle fucatalyst w

Annual Inspections of Older Vehicles: 

Inspect annually rather than every two years. 

Solid/Hazardous Waste: Increased scrappage, 

disposal and repair of faulty emission control parts. 

Promote rparts and 

Annual Inspections for High Annual Mileage Vehicles: 

Inspect annually rather than every two years. 

Solid/Hazardous Waste: Increased scrappage, 

disposal and repair of faulty emission control parts. 

Promote rparts and 

Add Visible Smoke Test: 

Include in the Smog Check test a visible smoke test to identify vehicles with excess PM emissions. 

Solid/Hazardous Waste: Increased scrappage, 

disposal and repair of faulty emission control parts. 

Promote rparts and 
May 7, 2007 Appendix E 42 

Potential Adverse Environmental Impacts of 

the Proposed 2007 State Strategies for the California SIP 

Strategy Description Potential Adverse Environmental Impacts Pote

Inspection of Light- and Medium-Duty Diesels: 

Include light- and medium-duty diesel vehicles in Smog Check to improve maintenance and reduce emissions. Repair poorly maintained or old emission systems. 

Solid/Hazardous Waste: Increased scrappage, 

disposal and repair of faulty emission control parts. 

Promote rparts and 

Inspection of Motorcycles:

Include motorcycle inspections as part of Smog Check. 

Solid/Hazardous Waste: Increased disposal of 

faulty emission control parts. 

Promote rparts and 

TRUCKS Cleaner In-Use Heavy-Duty Trucks:

Reduce excess emissions attributable to engine deterioration, poor maintenance, or tampering. Conduct visual, under-the-hood inspections of the emission control devices. 

Air: Use of Diesel Particulate Filters (DPFs) may 

accelerate conversion of nitric oxide (NO) to nitrogen dioxide (NO2). 

Air: Potential to increase ozone concentration, 

nitric acid, and secondary particulate matter 

formation. Air: Metals from various forms of catalyzed 

aftertreatment systems can be eroded and emitted as airborne PM, such as vanadium pentoxide from SCR. Air: Idling while waiting to be tested or while being tested could slightly increase all emissions. Air: Other secondary emissions are likely to include organonitrogen compounds, many of which are listed as TACs and are carcinogenic. 

Design DPNO2 conve

Design syefficiency. 

Ban use ometals and catalyst fozeolites) wvanadium. 

Design syefficiencie

Deploy alteformulationemissions compound
May 7, 2007 Appendix E 43 

Potential Adverse Environmental Impacts of 

the Proposed 2007 State Strategies for the California SIP 

Strategy Description Potential Adverse Environmental Impacts Pote

(continued) Cleaner In-Use Heavy-Duty Trucks Energy: Active regeneration of DPFs may include 

using external fuel or energy to burn off accumulated carbon and associated hydrocarbons trapped on filter. Energy: Maintaining the integrity of the add-on controls could extend the time period for the decrease in fuel economy. Hazards/Hazardous Materials: Increased idling at 

inspection stops has potential to expose anyone nearby to increased toxic diesel PM emissions. Noise: Increased number of trucks and idling at 

inspection stops could cause an increase in noise. Solid/Hazardous Waste: Waste ash from DPFs 

containing zinc may be generated. Solid/Hazardous Waste: Focus of measure is to maintain and repair devices, not replace them. If they are replaced, they may be sent to landfills. Transportation/Traffic: Existing roadside inspection 

program will likely be expanded and increase the number of locations where trucks will be pulled over and tested. 

assess depotential e

Promote ethough effto be neglDesign syefficiency. Locate insbuffer zonsensitive rLocate inswith a buffstop and sPromote rwaste manscrappageNone requImpact is nsignificant would not 
May 7, 2007 Appendix E 44 

Potential Adverse Environmental Impacts of 

the Proposed 2007 State Strategies for the California SIP 

Strategy Description Potential Adverse Environmental Impacts Pote

GOODS MOVEMENT Clean Up Existing Commercial Harbor Craft:

Reduce emissions by replacing or retrofitting old engines. 

Air: Increased levels of NO2 affecting ozone and 

secondary nitrate formation and nitric acid. May enhance formation of sulfates. Air: Selective catalytic reduction (SCR) of diesel 

exhaust using urea injection may increase ammonia emissions. Air: Reduction of fuel efficiency due to exhaust backpressures may require more fuel use resulting in increased CO2 emissions. 

Energy: Retrofitting post-combustion controls on 

engines may result in increased fuel use. Hazards/Hazardous Materials: Use of additives in 

diesel fuel or the use of alternative diesel fuels may create new hazards or enhance the hazard of diesel fuel. Solid/Hazardous Waste: Waste ash from DPFs 

containing zinc may be generated. Scrappage of older engines and their components. Water: Emulsified diesel fuel or fuel additives may 

increase soluble components in surface and subsurface water that could result from spillage and leakage from storage tanks. 

Use low-sAdjust urestoichiomerespect to Design syefficiencieDesign syefficiencieAny reformthe requirebe revieweevaluationwill be ideprocess. Promote rof materiaRequire spsafe stora
May 7, 2007 Appendix E 45 

Potential Adverse Environmental Impacts of 

the Proposed 2007 State Strategies for the California SIP 

Strategy Description Potential Adverse Environmental Impacts Pote

Auxiliary Ship Engine Cold Ironing and Other Clean Technology:

Reduce emissions from ships at berth with at-dock technologies such as cold ironing (electrical power) and other clean technologies. 

Air: Localized release of criteria pollutants and 

toxic air contaminants from power plants. Energy: Increased energy demand for shore-side 

power. Solid/Hazardous Waste: Emission filters may 

capture more emissions and require disposal of hazardous ash. 

Promote usources. Promote uand adopt source conEnsure prohazardous 

Cleaner Main Ship Engines and Fuels: 

Further reduce emissions from main engines through added retrofits such as selected catalytic reduction. Support efforts to accelerate use of cleaner ships and rebuilt engines. Require ships to use low sulfur diesel fuel in main engines. 

Air: SCR could increase releases of ammonia. 

Air: Diesel oxidation catalyst could form sulfates at higher temperatures. Air: Technologies such as low-NOx fuel injection, delayed injection timing and water vapor added to combustion chamber can cause slight increases in PM, hydrocarbons and CO2. Air: Distillation of heavy fuels can increase CO2 emissions at refineries. Solid/Hazardous Waste: Diesel oxidation catalysts 

which contain platinum are considered hazardous at end of life. 

Promote cUse low suDesign syefficiencieAir district must evaluquality impfeasible. Promote rfrom DOC

Port Truck Modernization: 

Retrofit or replace older heavy-duty diesel trucks that 

Air: Use of Diesel Particulate Filters (DPFs) may 

accelerate conversion of nitrous oxide (NO) to 

Design DPNO2 conve
May 7, 2007 Appendix E 46 

Potential Adverse Environmental Impacts of 

the Proposed 2007 State Strategies for the California SIP 

Strategy Description Potential Adverse Environmental Impacts Pote

service ports. nitrogen dioxide (NO2). Potential to increase 

ozone concentration, nitric acid, and secondary particulate matter formation. Energy: Increased use of fuel or energy for active 

regeneration of DPFs. Solid/Hazardous Waste: Waste ash from DPF 

containing zinc may be generated. 

Use renewPromote r

Locomotive Engines: 

Accelerate the introduction of cleaner line haul engines (Tiers 2.5 & 3) and concurrently rebuild older engines to cleaner standards using exhaust after treatment devices. 

Air: NOx would be slightly higher, and the SCRs 

would require urea. This could increase ammonia slip. Air: NO2 fraction may be increased with DPFs, total 

NO

X remains approximately the same. 

Air: SO

X could increase at higher temperatures as 

well as NO2. 

Energy: Diesel particulate filters, diesel oxidation 

catalysts, and SCRs can decrease fuel efficiency due to pressure loss and regeneration issues. After treatment technology would have the potential to reduce fuel efficiency. Hazards/Hazardous Materials: Possible high levels 

of zinc in DPF ash would need to be handled properly. Solid/Hazardous Waste: DPF’s will need to be 

disposed of once removed. Depending on catalytic material used during manufacturing, DOCs could become hazardous waste when they are removed. 

Design coexhaust teoptimum rutilized. None idenUse ultra lAdjust urestoichiomerespect to Install ammPromote rof materiaMaintain thtechnology working orschedule. nonhazardmaterial. 
May 7, 2007 Appendix E 47 

Potential Adverse Environmental Impacts of 

the Proposed 2007 State Strategies for the California SIP 

Strategy Description Potential Adverse Environmental Impacts Pote

CONSTRUCTION AND OTHER EQUIPMENT Cleaner In-Use Off-Road Equipment:

Establish fleet average emission limits for construction fleets requiring older engines be retrofitted or replaced with cleaner engines. 

Air: Diesel particulate filters, lean NOx catalysts 

and SCRs may have slight fuel economy penalty causing increase in CO2 emissions. 

Air: Diesel oxidation catalysts may form sulfates at 

high temperatures. Air: Diesel particulate filters may increase NO2

portion of NOx emissions. Air: Increased ammonia emissions from SCRs. 

Air: Secondary emissions from SCR are likely to include organonitrogen compounds, many of which are listed as TACs and are carcinogenic. Energy: Diesel particulate filters may require 

electricity to regenerate the filter. Hazards/Hazardous Materials: Metals from various 

forms of catalyzed aftertreatment systems can be eroded and bleed out into the environment, e.g., vanadium pentoxide from SCR. Solid/Hazardous Waste:Engines that are replaced 

through repowering could be sent to a landfill. 

Design syefficiency. Use low suto minimizUse filters 20 percen

ratio. Use an amdownstreaoxidize amDeploy altformulatioemissions compoundPromote crenewable Ban use ometals and catalyst fozeolites) wvanadiumSet guidelmethods ofilters, (i.escrapping landfill) 
May 7, 2007 Appendix E 48 

Potential Adverse Environmental Impacts of 

the Proposed 2007 State Strategies for the California SIP 

Strategy Description Potential Adverse Environmental Impacts Pote

(continued) Cleaner In-Use Off-Road Equipment:

Solid/Hazardous Waste: Catalyzed aftertreatment 

systems could be hazardous waste at the end of their useful life, depending on materials in catalytic coating. Solid/Hazardous Waste: Particulate filters could be hazardous waste due to ash containing metals, such as zinc. Also ash from periodic cleaning of filters could be considered hazardous for the same reasons. Water: Fluids (oils, etc) in engines that are 

replaced through repowering could leach into water. 

Depending aftertreatmprecious mReduce amsuch as by lubrication 

Ensure promaintenan

AGRICULTURAL EQUIPMENT Agricultural Equipment Fleet Modernization: Accelerate 

fleet modernization of agricultural equipment by replacing older, dirtier equipment with engines reflecting cleaner technologies. 

Although there is no specific proposal at this time for agricultural equipment, if an emission reduction strategy similar to the Cleaner In-Use Off-Road Equipment is pursued, the potential adverse environmental impacts would be expected to be the same. 

EVAPORATIVE & EXHAUST STRATEGIES New Emission Standards for Recreational Boats: 

Adopt catalyst-based standards for new outboard engines and evaporative emission standards for all sources of recreational boat evaporative emissions. 

None identified. None requ
May 7, 2007 Appendix E 49 

Potential Adverse Environmental Impacts of 

the Proposed 2007 State Strategies for the California SIP 

Strategy Description Potential Adverse Environmental Impacts Pote

Off-Road Recreational Vehicle Expanded Emission Standards:

Adopt exhaust and evaporative emission standards to reduce the amount of ROG from off-highway motorcycles and all-terrain vehicles. 

Air (exhaust): Potential for two-way catalysts to 

emit higher levels of NO2 affecting ozone, NO2, nitric acid, and secondary particulate. Noise: May increase if catalysts are used. 

Solid/Hazardous Waste (exhaust): Exhaust 

catalysts may contain hazardous materials including precious metals and benzene residue. Solid/Hazardous Waste (evaporative): Evaporative 

canisters may contain hazardous material including precious metals and benzene residue. Solid/Hazardous Waste (evaporative): Faulty control parts may be disposed of in landfills. 

Use of threreduce HCemissionsEncourage include soRequire prrecycling. Require prrecycling. Promote r

Portable Outboard Marine Tank Evaporative Standards:

Set evaporative emission standards to reduce emissions from tanks, hoses, primers bulbs and connecting devices. 

None identified. None requ

Refueling Gasoline Tank Evaporative Standards: 

Set standards for refueling gasoline tanks typically mounted on pickups and large recreational vehicles and used to refuel equipment and other smaller vehicles. 

Solid/Hazardous Waste: Replacement control 

parts, such as carbon canisters and low permeating hoses, may be sent to landfills. 

Promote r

Gas Station Refueling Hose Evaporative Standards:

Set evaporative emission standards to control permeation from gasoline dispenser hoses. 

None identified. None requ
May 7, 2007 Appendix E 50 

Potential Adverse Environmental Impacts of 

the Proposed 2007 State Strategies for the California SIP 

Strategy Description Potential Adverse Environmental Impacts Pote

Enhanced Vapor Recovery for Above Ground Storage Tanks: 

Adopt enhanced vapor recovery performance standards and specifications to control standing loss and working loss emissions from above ground gasoline storage tanks. 

None identified since replaced parts are usually reconditioned. 

None requ

CONSUMER PRODUCTS Tighten standards or require product reformulation for consumer products categories. 

Air: Potential small increase in greenhouse gases, 

depending on the alternative used. Air: Potential increase of TACs, depending on formulation. Hazards/Hazardous Materials: Reformulation for 

exempt VOC solvents may potentially increase flammability of solvent such as acetone and methyl acetate. Water: Any increase in PERC could negatively 

impact wastewater. 

Ensure thanot the soProhibit uswhere thereformulatExisting reconsumer that ensursignificant transport aNone iden
May 7, 2007 Appendix E 51 

Potential Adverse Environmental Impacts of 

the Proposed 2007 State Strategies for the California SIP 

Strategy Description Potential Adverse Environmental Impacts Pote

PESTICIDES Restrict VOC emitted from field fumigation, and set a reactivity standard or requirement for registration of some liquid pesticides. 

Agriculture: Acreage no longer fumigated to 

achieve VOC reductions could be converted to non-agricultural uses. Air: Methyl bromide and methyl isothiocyanate, 

which are ozone-depleting substances, may increase slightly in Ventura County. Solid/Hazardous Waste: Solid waste disposal may 

increase due to use of plastic tarpaulins under the proposed regulation. Water: Post-fumigation water treatments may 

require greater quantities of water use. 

Emission lareas primapplication The allowaonly in Veto be neglMost fumigtarpaulins measure. current disexpected tDrip chemsystems raapplicationthe use of undesirabtractor usein water usexpected t
May 7, 2007 Appendix E 52 

ECONOMIC IMPACT ANALYSIS 

Introduction

ARB staff has estimated the costs and economic impacts that could result in 

2014 from the proposed State Strategy to reduce emissions of oxides of nitrogen 

(NOx), reactive organic gases (ROG), fine particulate matter (PM2.5) and oxides 

of sulfur (SOx) in the South Coast and San Joaquin Valley State Implementation 

Plans (SIP). The emission reductions are needed to meet the attainment 

deadlines for the federal 8-hour ozone and PM2.5 standards. This analysis 

includes the costs and economic impacts of all proposed control measures under 

State jurisdiction, including passenger vehicles and trucks, goods movement, 

construction and mining equipment, engine exhaust and evaporation, and 

consumer products. It is important to note that the costs reflected in this section 

represent costs incurred in 2014 only although some measures will begin to be 

implemented prior to 2014 and continue after 2014. 

The proposed State Strategy measures, when adopted as rules or regulations, 

are likely to cause technological changes that could increase the production 

costs for regulated industries. Increased costs could have an initial 

contractionary effect on those industries, which in turn could affect other related 

industries either negatively or positively. For example, industries that provide 

supplies and services to affected industries could experience a reduction in 

demand for their products and services while suppliers of environmental products 

and services could experience an increase in their sales. The net effect on the 

California economy of these activities hinges on the extent to which products and 

services are obtained locally. Using an updated version of EnvironmentalDynamic Random Analysis model (E-DRAM)1

, staff estimated the net effects in 

2014 of these activities on the affected industries and the overall economy. The 

California industries affected most are those engaged in the production, 

distribution, sales, and use of cars and trucks, goods movement, off-road 

equipment and engines, and consumer products. 

The proposed State Strategy would bring about significant societal benefits, 

including less illness and medical expenses and fewer lost work and school days, 

to Californians. In its report to Congress in 1999, U.S. EPA found that the 

monetized benefits of the Clean Air Act exceed its compliance costs by a ratio of 

four to one.2 Using the findings in this report and considering that ARB 

regulations are usually more stringent and thus more costly, ARB staff estimates 

 

1

 For a complete description of E-DRAM, see Peter Berck, “The Economy-wide Effects of AirQuality Regulations,” prepared for California Air Resources Board, June 2005. Industrial sectors 

in the E-DRAM were further refined by David Roland-Holst and Ryan Kellogg, “Documentation of 

the 120 Sector SAM for California, 2003,” July 2006. 

2

 U.S. EPA Report to Congress, “The Benefits and Costs of the Clean Air Act 1990 to 2010,” 

November 1999. 
May 7, 2007 Appendix E 53 

that each dollar spent on clean air in California generates, on average, three 

dollars in societal benefits. 

Annual direct costs of all proposed State Strategy measures are estimated to be 

$4.6 billion in 2014. Increased costs that would result from the proposed State 

Strategy would reduce California’s economic output in 2014 from $2.948 trillion to 

$2.938 trillion (roughly $10 billion or 0.30 percent), personal income by $5 billion 

(0.30 percent), and California employment by approximately 37,000 jobs (0.20 

percent). These changes reflect a slight slow-down in the growth of the 

California economy from what it would be otherwise. From 2007 through 2014, 

California output is expected to grow by $74 billion, personal income by 

$45 billion, and employment by 198,900 per year. The impact of the proposed 

State Strategy would be a slight reduction in the annual growth rate of: economic 

output (from 2.85 percent to 2.80 percent); personal income (from 2.90 percent to 

2.88 percent); and employment (from 1.20 percent to 1.17 percent). 

Cost of Control Measures

Most control measures identified in the proposed State Strategy rely on the 

application of current technologies to achieve additional emission reductions. 

Some control measures, however, rely on the development of new technologies. 

The implementation of these control measures may fundamentally change the 

ways many products are manufactured, distributed, and used. Whether these 

changes require the reformulation of a consumer product or gasoline, retrofit of 

diesel trucks and buses, more stringent standards on in-board and outboard 

marine engines or modernization of port trucks, we assumed that they impose 

costs on businesses. This analysis provides estimates of those direct costs. 

ARB staff estimated the cost of each control measure using the most reliable 

information available. For some control measures, staff developed control costs 

directly based on the application of current technologies. For most control 

measures, however, staff estimated control costs indirectly by multiplying either 

the cost-effectiveness estimate by the emission reduction associated with the 

proposed State Strategy measure, or an estimate of the unit cost increase by the 

number of products that are projected to be used. 

The control costs in this report represent very rough estimates of the costs of the 

proposed State Strategy and may change when more specific regulatory 

language is developed. There is an extensive public process as part of the 

development of each proposed State Strategy measure into a regulation or 

program. ARB staff gathers detailed industry-specific information and assesses 

the potential costs to businesses, government, and consumers. The measures 

will be discussed at public workshops, and proposed regulations will go through 

the public hearing process as required by law. When specific regulatory 

language is developed, it will be possible to analyze potential costs and 
May 7, 2007 Appendix E 54 

economic impacts in more detail. This information will be presented with each 

regulatory proposal for Board consideration. 

Cost-effectiveness Estimates 

Cost-effectiveness is an estimate of the unit cost of reducing a pollutant which 

varies by pollutant and control strategy. The ARB cost-effectiveness estimation 

of its past control measures for ROG reductions from consumer products range 

from under $0.50 per pound ($1,000 per ton) to about $6 per pound ($12,000 per 

ton). For NOx+ROG reductions from mobile sources, the range varies from less 

than $0.50 per pound ($1,000 per ton) to about $3 per pound ($6,000 per ton). 

The figures below show cost-effectiveness estimates for California consumer 

products and mobile source control and fuel measures approved by the ARB in 

the late 1980s, 1990s, and early 2000s. 

Cost-Effectiveness Values for Various Consumer Products Regulations 

Cost-Effectiveness of Major Regulations

 Consumer Products

Automotive

Coatings

Consumer

Products

Consumer

Products

Aerosol Adhesives

Consumer Aerosol Coatings

Products

Aerosol Coatings

Consumer 

Products

Consumer 

Products Consumer 

Products

Consumer 

Products

Antiperspirants

Aerosol painting Architectural

Coatings

0.0

0.5

1.0

1.5

2.0

2.5

3.0

3.5

4.0

4.5

5.0

5.5

6.0

6.5

198819891990

1991

1992

1993

199419951996199719981999

2000

2001

2002

20032004

2005

2006

2007

Board Hearing Year

Dollars per Pound of VOC Reduction
May 7, 2007 Appendix E 55 

Cost-Effectiveness Values for Various Mobile-Source and Fuel Regulations 

In the early 2000s, ARB adopted a number of PM control measures. The costeffectiveness estimates for those measures ranged from $7 per pound ($14,000 

per ton) to $28 per pound ($56,000 per ton). 

For the purpose of this analysis, ARB staff made a very conservative assumption 

that future emission reductions will be more expensive to obtain than the past 

reductions. This is because firms are required to meet more stringent air quality 

standards or to control emission sources previously unregulated because of the 

high cost of control. In the past, however, businesses have always found 

innovative ways to meet standards at costs much lower than estimated by staff. 

We have no reason to believe that this trend will not continue in the future. For 

example, in 1988 the South Coast Air District estimated the cost of NOx 

reduction from a natural gas-fired power plant to be about $25,000 per ton 

compared to the industry estimate of $45,000 per ton. By 1995, when the rule 

requirements became effective, the actual cost of NOx control from power plants 

was about $12,000 per ton. Similarly, ARB staff estimated the cost to control 

evaporative emissions from vehicles to be about $170 per vehicle in 1990 while 

Cost-Effectiveness of Major Regulations

 Mobile Sources and Fuel

LSI Engine

In-Use Truck

Urban Bus

Small Off-Road

Marine Engine

2007 HDDE

Off-Road Cycle 2.4 HDDE

NTE & ESC

Off-Cycle LDT

2-Stroke Lawn

Off-Road Motorcycle

RFG 2

4-Stroke Lawn

OBD 1 Off-Road Diesel

0.4 Nox LDV

0.25 HC LDV

5g HDD

LEV Medium Truck

0.0

0.5

1.0

1.5

2.0

2.5

3.0

19851986198719881989199019911992199319941995

19961997199819992000200120022003

2004200520062007

Board Hearing Year

Dollars per Pound of Ozone Precursor
May 7, 2007 Appendix E 56 

the industry estimate was about $783 per vehicle. When the regulation was 

implemented, the actual cost of the regulation was closer to the lower estimate.3 

The cost-effectiveness estimates used for the proposed State Strategy ranged 

from a low of approximately $3,000 to a high of $32,000 per ton of ROG 

emissions reduced, from $3,000 to $43,000 per ton of NOx emissions reduced, 

and from $5,000 to $55,000 per ton of PM emissions reduced. The costeffectiveness estimates for SOx range from $8,000 to $43,000 per ton and are 

based on the use of clean fuels in ships and cold ironing of ship engines. These 

two measures are expected to reduce SOx emissions by 75 tons. The tables 

below illustrate how the cost of reducing a ton of either ROG or NOx would rise 

as more emission reductions are required. All cost-effectiveness numbers are in 

constant 2006 dollars. 

Cost-Effectiveness Ranking of the Statewide Control Measures for 

ROG Reduction 

Statewide Measures 

Average 

C/E 

(2006 

$/ton) 

Rank Estimated 

Statewide 

ROG Red. 

(TPD) 

Estimated 

Statewide 

Cumulative

ROG Red. 

(TPD)

More Stringent Cutpoints (Smog Check) $3,020 1 1.6 1.6 

Recreational Boat New Standards $4,754 2 14.3 15.9 

Consumer Products $4,852 3 30.6 46.5 

Low Pressure Evaporative Test $5,427 4 8.2 54.7 

Cleaner Line-Haul Locomotives $10,082 5 3.8 58.5 

Old Vehicle Retirement $11,426 6 5.9 64.4 

Off-Road Recreational Evaporative $13,385 7 20.1 84.5 

Cleaner In-Use Off-Road Equipment $13,600 8 7.1 91.6 

Reformulated Gasoline Program $14,253 9 16.0 107.6 

High Mileage Vehicles (Smog Check) $15,773 10 1.0 108.6 

Older Vehicle Inspection (Smog Check) $21,303 11 6.3 114.9 

Motorcycle Inspection (Smog Check) $22,780 12 4.1 119.0 

Cleaner In-Use Heavy-Duty Trucks $31,789 13 22.3 141.3 

 

3

 Lents, J.; Barnes, K.; Nikkila, N.; and Tatsutani, M.; The Regulation of Automobile Emissions: A 

Case Study. In Environmental Regulation and Technology Innovation: Controlling Mercury 

Emissions from Coal-fired Boilers. Northeast States for Coordinated Air Use Management, 

Boston, MA, September 2000. 
May 7, 2007 Appendix E 57 

Cost-Effectiveness Ranking of the Statewide Control Measures for 

NOx Reduction 

Statewide Measures 

Average 

C/E 

(2006 

$/ton) 

Rank Estimated 

Statewide 

NOx Red. 

(TPD)

Estimated 

Statewide 

Cumulative

NOx Red. 

(TPD)

More Stringent Cutpoints (Smog Check) $3,020 1 4.1 4.1 

Recreational Boat New Standards $4,754 2 1.3 5.4 

Clean Up Existing Harbor Craft $4,964 3 16.3 21.7 

Cleaner Ship Engines and Fuels $8,092 4 94.4 116.1 

Cleaner Line-Haul Locomotives $10,082 5 40.5 156.6 

Old Vehicle Retirement $11,426 6 4.8 161.4 

Cleaner In-Use Off-Road Equipment $13,600 7 27.8 189.2 

High Mileage Vehicles (Smog Check) $15,280 8 3.3 192.5 

Light/Med. Duty Diesels (Smog Check) $18,600 9 1.1 193.6 

Old Vehicle Inspection (Smog Check) $21,303 10 14.5 208.1 

Motorcycle Inspection (Smog Check) $22,780 11 1.1 209.2 

Cleaner In-Use Heavy-Duty Trucks $31,789 12 193.8 403.0 

Port Truck Modernization $32,536 13 2.0 405.0 

Auxiliary Ship Engine Cold Ironing $42,866 14 26.0 431 
May 7, 2007 Appendix E 58 

 

Cost-Effectiveness Ranking of the Statewide Control Measures for 

PM2.5 Reduction 

Statewide Measures 

Average 

C/E 

(2006 

$/ton) 

Rank Estimated 

Statewide 

ROG 

Red.(TPD) 

Estimated 

Statewide 

Cumulative

ROG Red. 

(TPD) 

Clean Up Existing Harbor Craft $4,964 1 0.8 0.8 

Cleaner Ship Engines and Fuels $7,553 2 11.7 12.5 

Cleaner Line-Haul Locomotives $10,082 3 1.3 13.8 

Old Vehicle Retirement $11,426 4 0.1 13.9 

Lt./Med. Duty Diesels (Smoke Check) $18,600 5 0.1 14.0 

Cleaner In-Use Off-Road Equipment $20,899 6 6.6 20.6 

Cleaner In-Use Heavy-Duty Trucks $31,789 7 12.7 33.3 

Truck Fleet Modernization $32,536 8 0.6 33.9 

Auxiliary Ship Engine Cold Ironing $42,866 9 0.4 34.3 

Visible Smoke Test (Smoke Check) $54,782 10 0.4 34.7 

Annual Costs 

Annual direct costs of all proposed State Strategy measures in 2014 are 

estimated to be approximately $4.6 billion. This represents about 0.2 percent of 

the California Gross State Product (GSP) in 2014. GSP measures the value of 

all goods and services produced in California in a given year. 

The table below provides estimates of total annual costs of the proposed State 

Strategy by source categories for the year 2014. Measures to reduce emissions 

from heavy-duty trucks alone account for 57 percent of annual State Strategy 

costs. Measures to reduce emissions from passenger cars and heavy-duty 

trucks combined account for 66 percent of the costs. 

Measures to reduce emissions from goods movement at California ports account 

for 26 percent of annual proposed State Strategy costs, of which about 81 

percent stems from the use of cleaner engines and fuel for ships and the 

application of cold ironing to auxiliary ship engines. The remaining annual State 

Strategy cost is associated with measures that intend to reduce emissions from 

construction equipment (4 percent), 
May 7, 2007 Appendix E 59 

off-road engine exhaust and evaporation (3 percent), and consumer products 

(1 percent). All costs are in constant 2006 dollars. 

Estimates of Total Annual Costs of the Proposed State Strategy for 2014 

 (Millions of 2006 Dollars) 

 Statewide 

Cost 

% of 

Total 

Passenger Vehicles: 396.6 8.6 

Smog Check: 

Low Pressure Evaporative Test 16.2 

More Stringent Cutpoints 6.3 

Annual Inspections for Older Vehicles 161.7 

Annual Inspections for High Annual Mileage Vehicles 24.8 

Add Visible Smoke Test 8.0 

Inspection of Light-Duty Diesels 8.2 

Inspection of Motorcycles 43.2 

Other: 

Old Vehicle Retirement 45.0 

Modifications to Reformulated Gasoline Program 83.2 

Trucks: 2,654.8 57.4 

Cleaner In-Use Heavy-Duty Trucks 2,654.8 

Goods Movement: 1,186.2 25.7 

Clean Up Existing Harbor Craft 31.0 

Auxiliary Ship Engine Cold Ironing & Other Clean Technology 422.4 

Cleaner Main Ship Engines and Fuels 534.0 

Accelerated Introduction of Cleaner Line-Haul Locomotives 167.9 

Port Truck Modernization 30.9 

Construction Equipment: 206.0 4.4 

Cleaner In-Use Off-Road Equipment 206.0 

Evaporative & Exhaust Standards: 125.3 2.7 

New Emission Standards for Recreational Boats 27.1 

Off-Road Recreational Vehicle Expanded Emission Standards 98.2 

Consumer Products: 54.2 1.2 

Tighten Standards 54.2 

Total 4,623.1 100.0 

 

Annual costs of the proposed State Strategy can also be classified by the type of 

pollutants. The table below provides a list of affected pollutants and their 

associated costs. As shown in the following table, NOx control accounts for 75 

percent of total annual costs, ROG control for 15 percent, SOx control for 5 

percent and PM2.5 for 5 percent. Of $4.6 billion total annual statewide costs, the 

cost for South Coast businesses and consumers will be $1.3 billion or 29 percent 

of statewide costs, and for San Joaquin Valley businesses and consumers it will 

be $757 million or 16 percent of the statewide costs. 
May 7, 2007 Appendix E 60 

Estimated Annual Costs of the Proposed State Strategy by Pollutants 

(Millions of 2006 Dollars)

Annual Costs Pollutant Statewide South Coast San Joaquin % of 

Total 

ROG $ 699.9 $ 227.8 $113.9 15 

NOx $3,449.7 $ 976.5 $608.3 75 

SOx $ 230.0 $ 61.1 N/A 5 

PM2.5 $ 243.5 $ 63.2 $ 35.1 5 

Total $4,623.1 $1,328.6 $757.3 100.0 

In order to estimate the total impact of the proposed State Strategy on the 

California economy, we also classified these costs according to the latest 

E-DRAM industrial sector classifications. The new model has 108 industrial 

sectors, of which six industrial sectors and one household sector would be 

affected directly by the proposed State Strategy. The next table provides 

estimates of total annual costs by affected industries and government. About 

1 percent of the total annual cost would be borne by government and about 

83 percent by transportation industry. The balance will be borne by the vehicle 

service industry (6 percent), construction industry (4 percent), boat and shipping 

repair industry (3 percent), petroleum refinery industry (2 percent), and chemical 

and drug industry (1 percent). 

Estimates of Total Annual Costs of Proposed State Strategy by Affected 

Industries for 2014 

(Millions of 2006 Dollars) 

Industry Annual Costs %Total

Boat and Ship Building Repair $ 125.3 3 

Chemical and Drugs Manufacturing $ 54.2 1 

Construction Industry $ 206.0 4 

Government Payments to Household $ 45.0 1 

Petroleum Refining $ 83.2 2 

Vehicle Services $ 268.4 6 

Transportation $3,841.0 83 

Total $4,623.1 100 

Economic Impacts

Control costs provide a means to estimate the direct expenditures that will be 

incurred by California businesses, governments, and individuals to meet the 

requirements of the proposed State Strategy. These costs would in turn bring 

about additional (indirect) changes in the California economy that may increase 

the overall costs. Increased control costs, for example, may result in higher 

product prices. California firms may respond by cutting back production and 
May 7, 2007 Appendix E 61 

decreasing employment. On the other hand, the planned control measures may 

also increase demand for environmental products and services, thus inducing 

firms supplying those products and services to expand their production and 

increase their hiring of workers. 

This change in costs will in turn affect other industries both negatively and 

positively. The net effect on the California economy of these activities hinges on 

the extent to which products and services are obtained locally. Using a 

macroeconomic model, staff estimated the net effects of these activities on 

affected industries and the overall economy. The California industries affected 

most are those engaged in the production, distribution, sales, and use of 

passenger vehicles and trucks, goods movement, construction and agricultural 

equipment, engine exhaust and evaporation, and consumer products. 

The economic model, however, does not account for the enormous benefits to 

California businesses and citizens that air quality regulations will bring. Improved 

air quality reduces illness and infant mortality and increases natural resources 

and work force productivity. Control programs also induce significant 

advancement of clean technologies. As stated earlier, ARB staff estimates that 

the benefits to California from currently adopted air pollution control measures 

exceed the costs by about three to one. That is, each dollar spent on clean air 

generates, on average, three dollars in societal benefits that improve the quality 

of life. 

Environmental-Dynamic Revenue Analysis Model (E-DRAM) 

The overall impact of all direct and indirect economic effects associated with the 

planned control measures are estimated using a computable general equilibrium 

(CGE) model of the California economy. A CGE model simulates various 

economic relationships in a market economy where prices and production adjust 

in response to changes in behavior resulting from regulatory changes. More 

specifically, it describes the relationships among producers, consumers, 

government, and the rest of the world. The CGE model used for this analysis is 

the latest updated version of the Environmental Dynamic Revenue Analysis 

Model (E-DRAM). E-DRAM was first developed as DRAM for the California 

Department of Finance 4

. The model can be used to measure the total impact of 

a change caused by a regulation in one industry on all other industries within 

California. The economic impact results are measured in terms of changes in the 

State output, personal income, and employment. 

The new model is based on a revised database called a social accounting matrix 

(SAM). The revisions to SAM include a calibration of the base year in the model 

to calendar year 2003 from fiscal year 1998-1999, an updating of energy data, 

and a more detailed sectoring of the California economy. The new E-DRAM 

 

4

 For a complete description of DRAM, see Berck, Peter, E. Golan and B. Smith, “Dynamic 

Revenue Analysis for California, California Department of Finance, Summer 1996. 
May 7, 2007 Appendix E 62 

divides the California economy into 174 distinct sectors, consisting of 108 

industrial sectors, two factor sectors (labor and capital), eight household sectors 

(classified by income level), nine composite goods sectors, one investment 

sector, and 45 government sectors (seven federal, 27 State, and 11 local), and 

one sector that represents the rest of the world. 

Data for the industrial sectors originated with the Bureau of Economic Analysis of 

the U.S. Department of Commerce, based on the Census of Business – a 

detailed survey of companies conducted in the U.S. every five years. The 

conversion of national data to updated California data is accomplished by Impact 

Analysis for Planning (IMPLAN), a program that primarily utilizes state-level 

employment data to scale national-level industrial data down to the size of a 

state. 

In much the same way as firms, households are also aggregated. California 

households were divided into categories based upon their taxable income. There 

are seven such categories in the model, each one corresponding to a California 

personal income tax marginal tax rate (0, 1, 2, 4, 6, 8, and 9.3 percent). Thus, 

the income for the “one-percent” household is calculated by adding up the 

income from all households in the one-percent bracket. 

Similarly, the expenditure of the one-percent household on agricultural goods is 

calculated by adding up all expenditure on agricultural goods for these 

households. The total expenditure on agricultural goods is found by adding the 

expenditure of all households together. 

Overall Economic Impact 

Increased costs of the proposed State Strategy will affect the California economy 

through many complex interactions. E-DRAM was developed to simulate many 

of these complex interactions. Using the model, ARB staff, in consultation with 

UC Berkeley researchers, conducted an assessment of the economic impacts of 

the proposed State Strategy on the California economy. 

The results shown below are based on preliminary emission reduction estimates 

and may change slightly. ARB staff will perform a confirmatory analysis with EDRAM prior to the hearing for Board approval. 

The following table summarizes the impact of the proposed State Strategy on the 

California economy in the year 2014, based on the E-DRAM results. We project 

the costs of the proposed State Strategy will reduce California economic output 

by roughly $9 billion (0.3 percent) and California employment by approximately 

37,000 jobs (0.2 percent) in 2014. Personal income would also decline by 

roughly $5 billion (0.3 percent) in 2014. 
May 7, 2007 Appendix E 63 

Impact on the California Economy of Proposed State Strategy in the Year 

2014 

(Billions of 2006 Dollars) 

California Economy Without State 

Strategy 

With State 

Strategy 

Difference 

(Impact) 

% Total

Output $2,948 $2,939 -$ 9 -0.3 

Personal Income $1,739 $1,734 -$ 5 -0.3 

Employment (thousands) 17,782 17,745 - 37 -0.2 

Conclusion

Total annual direct costs associated with the proposed State Strategy are 

estimated to be approximately $4.6 billion in 2014, 29 percent of which will be on 

South Coast residents and 16 percent on San Joaquin residents. Accounting for 

indirect costs, the proposed State Strategy is expected to reduce California 

economic output by about $9 billion, personal income by about $5 billion, and 

employment by about 37,000 in 2014. In the context of the State’s economy, the 

economic impact of the proposed State Strategy is small and is not expected to 

impose a noticeable impact. It should be noted here that the proposed State 

Strategy would bring about significant societal benefits to Californians. These 

benefits, which are difficult to express solely in economic terms, are not 

quantified in this analysis. Prior analyses have estimated that the benefits of 

California’s air quality regulations exceed the costs by a ratio of about three to 

one.