Comment Log Display

June 8, 2007


Chairman Bob Sawyer
California Air Resources Board (ARB)
1001 “I” Street
Sacramento, CA 95814 

Re:	San Joaquin Valley Air Quality Management Plan for Ozone
No-Constraints Analysis

Dear Chairman Sawyer:

	We write to express our deep concern with the current San Joaquin
Valley proposed attainment plan for ozone and its no-constraints
analysis. We believe the San Joaquin Valley Air District’s
assertion (which is based on their no-constraints analysis) that
it is impossible to get to clean air without the ‘black box’ may
be inaccurate and deserves more analysis. 
	We understand that a no-constraints analysis looks at control
options from the viewpoint that cost is not a consideration and is
intended to provide insight into the potential to reach clean air.
After reviewing both analysis conducted by the ARB on heavy duty
trucks for the San Joaquin Valley and the independent
International Sustainable Systems Research Center (ISSRC), we have
serious concerns that the San Joaquin Valley Air Pollution Control
District’s analysis is flawed. 
	Specifically, Chapter 7 of the SJV Plan says the no-constraints
inventory for 2020 for HDD trucks is 63, while ARB is 43 tons per
day. You can recreate the district’s number when you use grams per
vehicle emission rate for a new vehicle and apply it to the entire
of number of vehicles in the fleet, thereby inadvertently
increasing the Vehicle Miles Traveled (VMT) significantly.  We
believe the correct approach is to take the grams per mile
emission rate for a new vehicle and apply it to the total VMT in
the area. The ARB approach confirms this approach (ARB results are
43 t/d and the independent researchers at ISSRC calculates 48 t/d
because ISSRC emission factors are more conservative). Therefore,
we believe the ARB methodology confirms the validity of the ISSRC
methodology and confirms the flaw in the SJV District's
no-constraint analysis. 
	The table below shows the results of the ARB, SJV and ISSRC
calculations, illustrating that the district overestimates the
emissions achievable by approximately 30 tons/day from just three
categories in 2020. The difference is even more significant if an
earlier year is modeled and other sources are reviewed.

2020 No Constraints Emissions Calculation (tons/day)
Source Category	CARB1	District2	ISSRC
Heavy Duty Trucks	43	63	48
Passenger Vehicles & MDT	5	13	5
Farm Equipment	9	13	9
Total Difference from these three categories	-32	--	-27
		1The CARB analysis can be found on page 128 of their January
draft SIP.
		2The District analysis can be found in C of their proposed SIP.

 
The implications of this miscalculation are significant. The
District staff has indicated that it would be impossible to get to
attainment at any time based on their no-constraints analysis. 
However, if the ARB values were replaced by their calculations,
this no constraints inventory shows that it is possible to get to
or very close to attainment in 2017 or any year after. The full
ISSRC analysis shows that an overall no constraints analysis can
get in attainment in 2013 or any year after.

We understand that this information has been presented to the ARB
staff as well as the District on several occasions over the last
two months. The ARB staff has agreed that the methodology used by
the District is in error. 

We want to ensure this information is brought to the attention of
the ARB board members. We hope that it is helpful in determining
that additional time is needed to further analyze the SJV AQMP for
ozone in the hopes attainment of the federal health-based standard
can be achieved much sooner than 2024 as is currently being
proposed.

Sincerely,



Tim Carmichael
Coalition for Clean Air

Paul Cort
Earthjustice

cc: ARB board members