In order to achieve the improvement in air quality specified in
the AQMP, the control measures listed in the Plan must be adopted
and implemented within the timeframes set forth. In the event
that implementation of the AQMP is not providing adequate progress
and the interim emission reduction goals have not been met, the
District must take action to bring forward measures that are scheduled
for later adoption or implementation, or to implement certain
"contingency" control measures. These contingency measures
are control options that could be instituted in addition to the
AQMP control measures. Both state and federal Clean Air Acts require
that district plans include contingency measures. In addition,
several measures are identified for further evaluation which could
be adopted in the future if found to be feasible.
A total of 24 control measures have been identified and categorized
in two groups: Level I, or contingency measures, and Level II,
or further measures which are not feasible at this time but will
be reevaluated to determine if these measures are needed to attain
state air quality standards or potential future federal ozone
and particulates air quality standards. Table 9-1 lists the Level
I measures and Table 9-2 lists the Level II measures. In addition,
certain control measures from the 1994 AQMP are removed from this
Plan, having been determined to be infeasible. The following paragraphs
provide a summary of these control measures. A complete discussion
is included in Appendix IV, Section 6.
Level I measures are actions that can be implemented given existing
statutory authority. Such measures would need to be developed
and adopted as rules. The responsibility to adopt and implement
the Level I measures falls on the District, ARB, and U.S. EPA.
The measures would be implemented in the order specified in the
1997 AQMP until the shortfall is eliminated. A ranking of the
importance of each measure relative to ozone and/or carbon monoxide
planning requirements under the federal Clean Air Act is provided
in Table 9-1 for the Level I measures.
Level II measures are from the 1994 AQMP and have been determined
as being infeasible at this time, requiring further evaluation.
It has been further demonstrated that the federal ambient air
quality standards can be attained within the statutory time frames,
without these measures, which are listed in Table 9-2. The District
will continue to assess these measures to determine if in the
aggregate these measures will be beneficial in attaining state
air quality standards and potential future federal air quality
standards.
TABLE
9-1
Level I - Contingency Control Measures
AQMP Title Priority to Meet Responsible Issues
Measure CAA Requirements Agency
Number
Ozone CO PM10
CTY-1 Accelerated Implementation 1 2 4 District Resource
of Control Measures Availability
CTY-2 Command and Control Rules 2 3 5 District Resource
in Place of Educational Availability/
Outreach Program Measures Cost
Effectiveness
CTY-4 Enhanced Oxygenated Fuel -- 1 -- ARB Potential
Content for CO NOx Emission
Increases
CTY-12 Emission Reductions from -- -- 1 District Emissions
Paved Roads (Curb and Reduction
Gutter/Chemical Effectiveness
Stabilization) (Formerly
BCM-01 (1D & 1E))
CTY 13 Further Emission -- -- 2 District Emissions
Reductions from Reduction
Construction and Effectiveness
Demolition Activities
(Rule 403) (Formerly
BCM-02)
CTY 14 Emission Reductions from -- -- 3 District Unquantified
Miscellaneous Sources Emission
(Weed Abatement) (Rule Reductions
403) (Formerly BCM-05)
TABLE 9-2
Level II - Control Measures for Further Evaluation
AQMP Measure Title Pollutant Principal
Number Reason*
CMB-01 Phase II RECLAIM NOx, SOx 2
CMB-02 Emission Reductions from Combustion NOx 1,2, 3
Equipment at Non-RECLAIM Sources
CMB-08 Control of Emissions from Gas-Fired PM10 1, 2, 3
Petroleum Refinery Process Heaters
CMB-10 Emission Reductions from Glass NOx 3
Melting Furnaces (Non-RECLAIM)
CMB-11 Emission Reductions from NOx 3
Non-RECLAIM Incinerators
CTS-02A Emission Reductions from Electronic VOC 3
Components Manufacturing
CTS-02D(1) Further Emission Reductions from VOC 3
Marine Coating Operations (Rule
1106)
CTS-02D(2) Further Emission Reductions from VOC 3
Pleasure Craft Coating Operations
(Rule 1106.1)
CTS-02G Further Emission Reductions from VOC 3
Paper, Fabric, and Film Coating
Operations (Rule 1128)
CTS-02I(1) Further Emission Reductions from VOC 2,3
Screen Printing Operations (Rule
1130.1)
CTS-02J Further Emission Reductions from VOC 2,3
Wood Products (Rule 1136)
CTS-02K Further Emission Reductions from VOC 3
Aerospace Assembly and Component
Manufacturing Operations (Rule
1124)
* 1= Not cost-effective (H&SC 40922(a))
Not economically feasible (PRC21061.1)
2=Technically infeasible (H&SC 40922(b))
Not technically feasible (PRC21061.1)
3=Minimal emission reduction potential (H&SC40922(b))
Not feasible due to social impact considerations and cost of administrative
burden. (PRC21061.1)
4=Low public acceptability (H&SC40922(b)
Not feasible due to social impact considerations (PRC21061.1)
TABLE 9-2
(Concluded)
AQMP Measure Title Pollutant Principal
Number Reason*
CTS-02L Further Emission Reductions from VOC 3
Motor Vehicle Assembly Line Coating
Operations (Rule 1115)
PRC-02 Further Emission Reductions from VOC 3
Bakeries (Rule 1153)
PRC-05 Emission Reductions from Malt VOC 3
Beverage Production Facilities and
Wine or Brandy Making Facilities
MON-02 Excessive Car Dealership Vehicle VOC, CO 2
Starts
MON-04 Excessive Curb Idling VOC, CO 2
CTY-7 Stringent Emission Limits for Goods All 5
Movement Activities (Aircraft, Pollutants
Rail, and Marine Vessels)
* 1= Not cost-effective (H&SC 40922(a))
Not economically feasible (PRC21061.1)
2=Technically infeasible (H&SC 40922(b))
Not technically feasible (PRC21061.1)
3=Minimal emission reduction potential (H&SC40922(b))
Not feasible due to social impact considerations and cost of administrative
burden. (PRC21061.1)
4=Low public acceptability (H&SC40922(b)
Not feasible due to social impact considerations (PRC21061.1)
5=Economic concerns, implementation authority
There are 18 measures designated as Level II contingency control
measures. The basis for each measure's designation as Level II
contingency is described below.
CMB-01 Phase II RECLAIM would expand the RECLAIM program
to facilities with NOx and SOx emission reductions below 4 tons
per year. Expanding the RECLAIM program may pose an administrative
burden to the District and some of the subject facilities. However,
the feasibility of this approach should be reevaluated in the
future to determine if circumstances have changed.
CMB-02 This measure includes unpermitted miscellaneous
combustion sources, curing and drying ovens, after burners, metal
melting furnaces, and internal combustion engines. Emission reductions
from non-RECLAIM combustion sources would involve the regulation
of several tens of thousands of non-permitted emission sources.
Implementing the control measure would require the identifying
and on-going enforcement of thousands of currently unpermitted
combustion sources at mostly small business sites. In addition,
estimates of control technology and associated costs may be difficult
due to the diverse nature of small businesses using these deminimus
combustion equipment. For some devices, the control costs are
also expected to be over the acceptable cost-effectiveness threshold
for rule development. At this time there is no technology for
further control of the internal combustion engines which would
be part of this control measure. Therefore, the administrative
burden and lack of control technology make this measure infeasible
at this time.
CMB-08 Control technology to reduce PM10 emissions from
this source category is expensive and difficult to install and
operate. In addition to cost and technology considerations, the
total mass emission reductions are also small from refinery process
heaters, due to other controls already in place to reduce NOx
and SOx emissions. Uncertainty as to the potential emission reduction
technology prevents the District from establishing an emission
reduction factor for this control measure. It is believed also
that the emission reductions would be minimal. This measure is,
therefore, considered neither technically nor economically feasible
at this time.
CMB-10 Glass melting furnaces not subject to the RECLAIM
program represent a small emission source category. Potential
emission reductions from this category, even with a high control
efficiency, would be low. The emission reductions expected from
this control measure are less than 20 pounds per day of NOx. The
administrative burden of bringing such a rule forward, at this
time, is not justifiable for the minimal emission reductions likely.
CMB-11 Non-RECLAIM incinerators represent a small emission
source category. The further emission reduction potential which
could be achieved by this control measure would, therefore, be
relatively low regardless of the control efficiency factor. This
control measure has an estimated emission reduction of 0.11 ton/day
of NOx. The administrative burden of developing a rule is not
justified at this time for such a minimal emission reduction.
CTS-02A Electronic component manufacturing represents a
small emission source category. The emission reduction potential
which could be achieved by this control measure would be relatively
low regardless of the control efficiency factor. This control
measure has an estimated emission reduction of 0.17 tons/day.
The administrative burden of developing a rule is not justified
at this time for such a minimal emission reduction.
CTS-02D(1) and CTS-02D(2) These measures would further
regulate emissions from marine vessel and pleasure craft coatings
respectively. The emission reductions which could be expected
from the two control measures combined represents a total of approximately
60 pounds of VOC per day. The administrative burden of developing
a rule is not justified at this time for such a minimal emission
reduction.
CTS-02G This contingency measure calls for further emission
reductions from paper, fabric and film coating operations. The
estimated emission reductions which might be achievable from this
measure are also relatively small (340 pounds of VOC per day).
Considering the costs of rule development and implementation that
would be required of the District, as well as high compliance
costs for minor emission reductions, implementation of this measure
is not feasible at this time.
CTS-02I(1) The potential emission reductions which could
be achieved from implementation of this control measure are minimal,
representing a 20% reduction, when compared to the administrative
burden of developing the rule. There is, however, technical uncertainty
associated with the control technology to further control VOC
emissions from screen printing operations. Therefore, it has been
determined that this control measure is infeasible and will be
delayed due to cost, and administrative burden relative to the
minimal gain in emission reductions.
CTS-02J Due to concerns regarding the availability and
feasibility of the required coating technology, the measure has
been moved to Level II contingency status and will continue to
be evaluated. Staff will propose further considerations when technology
developments are found to be acceptable, cost-effective and technically
feasible for this industry group.
CTS-02K Aerospace assembly and component manufacturing
operations are already regulated to a great extent. The further
emission reductions which would be targeted by this control measure
are minimal, amounting to approximately 120 additional pounds
of VOC per day. The administrative burdens of rule development
are not justified at this time for such a minimal emission reduction.
The measure has, therefore, been moved to a Level II contingency
and will be subject to future evaluation.
CTS-02L This contingency measure would further regulate
the emissions from motor vehicle assembly line operations, of
which there is currently only one in the Basin. The expected emission
reductions of 40 pounds per day of VOC. The administrative costs
of rule development do not justify pursuing the measure at this
time.
PRC-02 This measure's aim of achieving further emission
reductions from bakery operations would require the application
of controls on low-emitting bakeries. Larger emitting bakeries
are currently controlled by the terms of existing Rule 1153. The
remaining bakeries represent a small source category and the expected
emission reductions would be minimal (approximately 160 pounds
per day of VOC). At this time it is more cost effective to proceed
with the implementation of other measures which can achieve a
greater emission reduction at equal or lesser administrative cost.
PRC-05 The malt beverage, wine and brandy producing facilities
within the District's jurisdiction represent a minimal emissions
source category. The anticipated emission reductions from this
control measure would be less than 20 pounds per day. The administrative
burden of proceeding with implementation of this measure is not
at this time justified by the minimal emission reductions that
would be gained.
MON-02 This control measure seeks emission reductions due
to excessive starts of new and used vehicles at car dealerships.
The measure would be implemented either through District regulations
or local ordinances. There were no emission reduction estimates
for this measure in the 1994 AQMP. Enforcement issues do not justify
pursuing this measure at this time.
MON-04 This control measure seeks emission reductions due
to excessive curb idling. The measure would be implemented through
local ordinances. There were no emission reduction estimates for
this measure in the 1994 AQMP. Enforcement issues do not justify
pursuing this measure at this time.
CTY-07 This contingency measure seeks further emission
reductions through limiting goods movement activity if the Basin
does not attain an applicable federal air quality standard. Several
concerns are raised with such a program including economic impacts
to the region and the appropriate implementation authority. As
such, further evaluation to the feasibility and cost-effectiveness
of this measure is needed.
Table 9-3 lists the measures contained in the 1994 AQMP which
are recommended for deletion. These measures have been determined
to be infeasible, based on cost, technical, social acceptability,
legal authority, and administrative factors.
TABLE 9-3
Measures Removed*
AQMP Measure Title Pollutant Principal
Number Reason**
CMB-05 Clean Stationary Fuels NOx, SOx, 2, 3
PM10
CTS-01 VOC RECLAIM VOC 4
CTS-02F Further Emissions Reductions from VOC 1
Motor Vehicle and Mobile Equipment
Non-Assembly Line Coating
Operations (Rule 1151)
CTS-02I(2) Further Emission Reductions from VOC 1
Graphic Arts Operations (Rule
1130)
ISR-01 Special Event Centers VOC, NOx, 4
SOx
ISR-02 Shopping Centers CO, PM10 4
ISR-03 Registration and Commercial CO, PM10 4
Vehicles
ISR-04 Airport Ground Access CO, PM10 4
ISR-05 Trip Reduction for Schools CO, PM10 4
PRC-04 Emission Reductions from Rubber VOC, PM10 3
Products Manufacturing
* These measures and the reasons for their removal from the Plan
are further discussed in the Environmental Impact Report for the
AQMP.
** 1= Not cost-effective (H&SC 40922(a))
Not economically feasible (PRC21061.1)
2 = Technically infeasible (H&SC 40922(b))
Not technically feasible (PRC21061.1)
3 = Minimal emission reduction potential (H&SC 40922(b))
Not feasible due to social impact considerations and cost of administrative
burden. (PRC21061.1)
4 = Low public acceptability (H&SC 40922(b)
Not feasible due to social impact considerations (PRC21061.1)
5 = Limited authority per SB 772 (Hurtt) and SB 437 (Lewis)
TABLE 9-3
(Concluded)
AQMP Measure Title Pollutant Principal
Number Reason**
RFL-01 Emission Reductions from Utility VOC 3
Equipment Refueling Operations
RFL-03 Emission Reductions from Pleasure VOC 2
Boat Fueling Operations
FSS-01 Stage I Episode Plans All 5
Pollutants
CTY-06 Parking Cash-Out for Employers All 5
Having 25 or more Employees Pollutants
* These measures and the reasons for their removal from the Plan
are further discussed in the Environmental Impact Report for the
AQMP.
** 1= Not cost-effective (H&SC 40922(a))
Not economically feasible (PRC21061.1)
2 = Technically infeasible (H&SC 40922(b))
Not technically feasible (PRC21061.1)
3 = Minimal emission reduction potential (H&SC 40922(b))
Not feasible due to social impact considerations and cost of administrative
burden. (PRC21061.1)
4 = Low public acceptability (H&SC 40922(b)
Not feasible due to social impact considerations (PRC21061.1)
5 = Limited authority per SB 772 (Hurtt) and SB 437 (Lewis)
The rationale for deleting these 1994 AQMP control measures from
the 1997 AQMP is explained in the following paragraphs.
CMB-05 This control measure was intended to achieve emission
reductions by requiring the use of clean fuels in stationary sources.
The NOx emission reductions which were expected from this control
measure will be achieved through the implementation of existing
NOx control rules. Additionally, due to issues of safety and operating
requirements, it is not feasible in all circumstances to completely
eliminate the option for stationary sources to use standard fuels
as a back up fuel during emergencies or other unexpected situations.
CTS-01 The proposal to implement a RECLAIM program for
VOC emissions has been placed on hold at this date. In place of
CTS-01, substitution control measures from the 1994 AQMP are proposed
to be implemented in the 1997 AQMP. This measure is not considered
socially feasible at this time.
CTS-02F This control measure calls for further control
of sources currently regulated under Rule 1151 sources. The measure
would affect a large number of very small operations. The costs
of implementing the measure, estimated at $50,600 per ton, are
high and the emission reduction potential is minimal in comparison
to the number of sources involved. The measure is, therefore,
not considered to be feasible due to its high impact on small
operations and the costs of implementation.
CTS-02I(2) The further control of emissions from graphic
arts operations was found not to be cost effective. The estimated
cost per ton would exceed $100,000. Given the existing control
on graphic arts operations and the control cost this additional
measure would place on these operations compared to the amount
of emission reductions that would be achieved, the measure has
been dropped.
ISR-01 through ISR-05 These control measures would
have required actions by indirect sources to reduce emissions
resulting from vehicle trips. These indirect sources do not have
any control over the actions of motorists driving to their facility,
unlike employers. Moreover, except in the case of schools, there
is not a continuing, repetitive pattern of trips to these sources.
For these reasons, it is much more difficult for these sources
to reduce trips through ridesharing programs than it is for larger
employers. Over the last few years, the legislature has consistently
restricted, and bills have been introduced, to abolish district
authority over indirect sources. This contributes to the conclusion
that these measures are infeasible due to social considerations.
0In addition, 1996 state legislation eliminated the specific transportation
performance standards which motivated the inclusion of these measures
in previous plans.
PRC-04 The emission reduction potential from control of
rubber products manufacturing envisioned in this measure is below
20 pounds per day. The minimal emission reduction potential of
this measure is outweighed by the costs and administrative burden
of adopting the measure.
RFL-01 This control measure would require the design and
use of a fuel tank interface for utility equipment to accept only
an interlocking fuel spout. In addition, gasoline dispensing facilities
would be required to only dispense gasoline into approved non-spill
containers. Further evaluation of this measure indicates that
at this time, this measure is not cost-effective and is administratively
burdensome relative to the potential emission reductions. Enforcement
of this control measure would require monitoring thousands of
consumers that fill small fuel containers and then transfer that
fuel into utility equipment, such as lawn and garden equipment.
The cost and time required for the District or ARB to certify
or approve fuel tanks or nozzles is not an effective use of resources
at either agency or the industry, given the modest potential emission
reduction of 80 pounds per day. Thus, the administrative burden
and cost to enforce this control measure would be extensive relative
to the minimal emission reduction potential of this measure.
RFL-03 Upon further analysis, implementation of this measure
has been determined to be technically infeasible and not cost-effective.
Through various meetings, the U.S. Coast Guard has raised issues
regarding regulating pleasure boat refueling operations and has
expressed concern for public safety. In addition, it has become
apparent that most pleasure boat fueling operations occur at conventional
gasoline dispensing facilities as compared to marinas, which typically
have only one fueling facility.
FSS-01 This further study measure was proposed to develop
programs to reduce emissions under Stage I episode conditions.
State law has removed the District's authority to require rideshare
programs. As such, this measure has been removed from the 1997
AQMP.
CTY-06 This contingency measure was proposed to reduce
emissions through implementation of parking cash-out programs
for employers having 25 or more employees. State law has removed
the District's authority to require rideshare programs. As such,
this measure has been removed from the 1997 AQMP.
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