Antonio-Aquino 1

Alma Antonio-Aquino
Writing 39C
Jaya Dubey
1 December 2015
The Possible Solution to Fresnos and the San Joaquin Valleys Air Pollution Problem
ABSTRACT
The San Joaquin Valley Air Pollution Control District approved the 2015 Plan for the
1997 PM2.5 Standard( 2015 CA SIP) in April 16,2015, which proposes the attainment of 15
micrometers annual PM2.5 standards in 2020 and the 65 micrometer 24-hour PM2.5 standard in
2018 through various scientific estimates of emission reduction programs (Corey). Although the
California Air Resource Board approved this plan, it is still pending approval from the U.S EPA.
The scientific data supports the predicted estimates in order for Fresno and the San Joaquin
Valley to reach its desire attainment levels in the proposed years, however, not all involved
parties are convinced of its feasibility. Does this plan have the potential to solve what previous
policies have failed to accomplish? If so at how and at what cost?
To answer these questions I summarize my extensive research into an essay that will
cover the main points of the air pollution problem and its proposed solution. In this paper I will
briefly describe the problem whose solution I am advocating. The essay contains (1) background
information on the problem, (2) the force behind the proposed solution, (3) the most significant
efforts proposed by the solution, (4) opponents and supporters, (5) cost-benefit-analysis, (6) a
second less effective solution, and (6) recap of the problem and the proposed solution.
Throughout the essay I plan to make it clear that although this plan seems to be a perfect solution
it in fact, is not, it also has flaws and faces roadblocks which could result in its dismissal instead

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of its approval. My purpose for writing about this topic is to advocate for approval of 2015 CA
SIP, because despite its costs and its complications, it seeks to improve the air quality in ways
which they have positive long term impact.
Introduction
Historically, Fresno has consistently been ranked amongst the most polluted cities in the
nation. However, this problem has recently been exacerbated by the worsening drought
conditions in the area which are not allowing the area to meet the state air quality standards both
on its 24-hour basis and on its annual basis. The drought conditions have not only threaten the
health of the citizens who are affected by air changes but also have harm the achievement goals
of air pollution policies already in place.
Air pollution in this area usually
involves the accumulation of particulate
matter, vehicle emissions, and chemical
compounds year-round but especially
during the winter when the area is
affected by an inversion layer. The

Figure 1: The high pressures in the valley create an

inversion layer refers to a warm layer

inversion layer. The warm air layer settles over the

that settles over the area during the

valley trapping smog and restricting air flow, until

winter in the valley, restricting the air

the sun warms the cool air trapped under the warm

flow of Fresno and cities in the valley

layer enough to dissipate the layer. The

thus inducing the build up of pollutants

accumulation of pollutants is higher during the

in the layer underneath the warm layer,

containing pollutants and causing the air

winter season when its harder for the cooler air to

get warm enough to dissipate the layer barriers.

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quality to worsen. This inversion layer can be seen in figure 1. The inversion layer that settles
over the area cannot be reversed, however, reducing the pollutants in the area can diminish the
accumulation during the winter improve air quality year round.
The Fresno area constantly fails to achieve the state air quality standards as a result of a
large accumulation of air pollutants largely caused by mobile sources, industrial businesses, and
agricultural practices. The most harmful pollutant in the Fresno area is particulate matter 2.5
(PM2.5),a complex mixture which can be generated directly in the form of soot, smoke, and dust
or can form in the atmosphere from the reactions of precursor gases, including NOx, SOx,
VOCs, and ammonia (Velasco) These gases are prominently emitted in the San Joaquin Valley,
which makes it imperative for the region to implement a regulation plan. Nitrogen oxides are
pollutants caused by mobile sources; in the San Joaquin Valley heavy duty diesel truck emissions
are the main contributors to the current
air pollution problem. In fact Figure 2

Figure 2: Sources of NOx Emissions within the San

Joaquin Valley Air Basin

allows us to see that heavy duty trucks

are responsible for 43% of the daily
NOX emissions in the San Joaquin
Valley, while the transportation sector
as a whole is responsible for 76% of the
daily NOx
emissions as well 56% of the VOC
pollution (Air Pollution: Where Does It
Come From?). This industry is the

Source: California Emissions Projection Analysis Model

NorCal v1.04 2013 Annual Average

Figure 3: The pie chart above shows vehicular

emissions per day. Heavy duty trucks used by local
Fresno agriculture business emit 130 tons per day of
NOx, 43% of the daily total.

largest contributor of the air pollution problem in the San Joaquin Valley as well as the largest

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contributor linked to causing many health problems. Particulate matter 2.5 caused by diesel
exhaust, found in the San Joaquin Valley, has particularly been linked to having the potential of
causing cancer, respiratory and cardiovascular problems, because it is a microscopic particle that
can be easily inhaled and become trapped in the body. The large amounts of PM2.5 in Fresno
county has increased health disease rates, in fact 1 in 6 children have asthma, and 1 in 8 adults is
currently afflicted by either a pulmonary or a cardiovascular disease. Currently in Fresno
County, approximately 176,000 children and adults have been diagnosed with asthma (Fresno
County Asthma Profile) .Along with mobile sources, stationary sources also contribute to the air
pollution of the area, and they account of for 23% of the areas VOC pollution. (Air Pollution:
Where Does It Come From?) .Although stationary and area pollution come from small sources of
pollution, the areas which are widely known to contribute to this pollution are industrial
businesses, homes, and agricultural practices. The stationary source pollutants which can be
more easily reduced, in this case are polluting practices from homes and agricultural practices.
The rest of the air pollutants that contribute to the current air pollution in the San Joaquin Valley
are naturally occurring pollution. The large accumulation of these pollutants in the past three
years has left Fresno unable to comply with federal standards, and thus has been deemed an nonattainment areas.
Currently, the Air Resource Board along with Cal EPA and the U.S EPA are working to
achieve attainment goals proposed in the California State Implementation Plan of 1997, and
approved in 2011. This State Implementation Plan (SIP) proposed that the San Joaquin Valley
region meet the air pollution standards in California by April 2015, those standards being that the
area had to comply with having the annual standard of 15 micrometers, and 24-hour PM2.5
standard of 65 micrometers. It took years for this SIP to be approved by U.S EPA, despite this

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fact, the plan effectively worked in slowly decreasing the pollution in the area by as much as
30%. In fact most regions had reach the 24 HR PM2.5 of standard of 65 micrometers, but as of
2013 when the drought begun to be more noticeable the improvements begun to decrease
(Velasco). The drought had not been factored into the attainment plan, and thus the ARB had not
foreseen that it would curtail their efforts made towards the attainment plan. Although the ARB
managed to get an extension for their attainment plan, the implemented plan is no longer as
applicable as it was when it was being implemented before the drought. It is important to know
that although there was progress working with this plan, Fresno was unable to achieve attainment
even before the drought.
In response to the immensity of the problem that the San Joaquin Valley is now facing,
the San Joaquin Valley Air Pollution Control District developed the 2015 PM2.5 SIP, which they
proposed to the ARB, the agency in charge of regulating air quality standards in the state.
Although the ARB approved the SIP as a potential plan to be implemented in the state, the ARB
is now in charge of getting this SIP approved by US EPA. If approved by U.S EPA, this SIP will
ensure that by 2018 the 24 hour PM2.5 standards will be attained and that the annual PM2.5
standards will be met in 2020 not only in Fresno and the San Joaquin Valley, but also all the
other areas that are currently categorized as non-attainment areas for 2015 in California. The
2015 SIP proposes to achieve this by implementing stricter regulations in its state mobile source
control programs and its district control programs, and by providing grants through its incentive
programs. The proposed SIP has the potential not only to improve the air quality in the region
but also to make headway in ways to deal with air pollution as well as to protect citizens against
adverse health impacts of exposure to PM2.5. This is highly important given that there has been
a rise in the amount of citizen negatively affected by air in the region. Although this plan seems

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like a great solution for the ongoing problem, it first faces the obstacle of being passed by the
EPA, and then it faces the hurdles that come with implementation, including multi-agency
cooperation and opposition such as that coming from the Western States Truck Association
(WSTA), whom had filed a lawsuit in 2008 when a similar SIP was under approval. However, if
approved by EPA, the 2015 SIP will not only effectively reach the attainment goals but also has
great potential to reduce health care cost.
The 2015 SIP was developed by San Joaquin Valley Air Pollution Control District to
address the increase of PM2.5 in the Fresno region, specifically capturing the root causes of the
problem and basing its solution on scientific modeling to propose the best available control
measures, making it one of the best solutions proposed for this problem. Unlike the Super
Pollutant Emission Reductions Act of 2015, which also targets non-attainment areas, the 2015
CA SIP is less broad and more specific in providing a solution with positive long term impact.
One of the most important part of the proposed solution to improve air quality is advocating for
stricter regulations to reduce NOx
emissions from off-road and on-

Figure 3: NOx Emissions vs Ammonium Nitrate Trends at

Bakersfield and Fresno

road vehicles and equipment.

Studies performed by the ARB
show that reducing NOx emissions
from mobile sources are in fact,
more, effective in reducing PM2.5
than the regulation of any other
gas.

Studies by the ARB have shown that although NOx

reductions do lead to reduction in ammonium nitrate, NOx
reductions have been more effective in reducing PM2.5.

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In fact, Figure 3, details the success in previous years, before the drought, that the
reduction of NOx emissions extensively decreased the amount of PM 2.5 in severe nonattainment areas. Meaning that in order to reach the attainment level proposed for 2018 and
2020, the San Joaquin Valley has to follow similar control measures, but perhaps a bit stricter.
The regulatory efforts to reduce NOx emissions include the Advanced Clean Car program, the
California Truck and Bus Regulations, and the Off-road Regulation. The Advanced Clean Cars
program focuses on curtailing emissions from passenger cars to current air quality and climate
change needs, requiring that all vehicles created between 2015 and 2025 emit 75% less NOx,
smog-forming pollutants, and greenhouse gases than cars manufactured before 2010. The
California Truck and Bus Regulation and the Off-road Regulation both focus on reducing the
NOx emissions caused by diesel engines, such as heavy-duty trucks, buses, fleets, and
equipment, by mandating these engines to be retrofitted or replaced by technology which include
PM2.5 filters which would significantly help diesel exhaust particulate matter emissions.
It is clear that the 2015 SIP is not a clear cut solution, given that in order to reach the
attainment levels, various agencies need to be involved, although this is a potential drawback it is
also an advantage because that means the problem is being addressed in many levels, not only at
a state level, but also at a local level. As part of the solution, the 2015 SIP also proposes that the
district control programs, such as the San Joaquin Valley Air Pollution Control District reduce
soot, smoke, and VOCs by regulating the amount of wood burning days in the Valley. As well as
using incentive programs to replace wood burning appliances, such as wood burning heaters,
boilers, fireplaces, and furnaces, with newer technologies that would greatly reduce pollutants of
these appliances during the winter, when the reduction of these pollutants is more imperative to
improving the air quality of the area (Velasco). Incentive programs, like the ones proposed at the

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local level are in fact, a, huge part of cultivating change in the proposed plan, these incentive
programs have the potential to block some of the opposition because it makes the solution seem
feasible. In fact, the district has set aside $156 million in incentive funding from local, state, and
federal funding sources to reduce local emissions (Velasco).Currently, the two statewide
incentive programs that are aiding efforts to reduce NOx emission are the Goods Movement
Emission Reduction Program (GMERP) and the Carl Moyer Memorial Air Quality Standards
Attainment Program (CMMAQSAP) both regulated by the Air Resource Board (ARB). The
GMERP focuses on providing grants to freight vehicles, such as boats and trucks, it is a billiondollar incentive program that is focused on improving the attainment level in five specific air
basins in California, the San Joaquin Valley being of them, in the next 5 years (Goods Movement
Emission Resource Program). The CMMAQSAP is also focused on reducing emissions caused
by diesel engines, however it focuses on both off-road and on-road vehicles and equipment, by
providing grants for qualifying engines who need help to comply with the impose state
regulations (Carl Moyer Memorial Air Quality Standards Attainment Program). Together these
programs have provided significant reductions in NOx and have the potential of greatly reducing
diesel particulate matter by 2020 and beyond the years of attainment. Although, these are only
some of the techniques proposed on the 2015 CA SIP they are the most important and impactful
because they will regulate the precursor gas that can be more easily reduced and the gas that is
the largest factor present in not only in Fresno, the San Joaquin Valley, but also in the entire
state.
Although the 2015 CA SIP has supporters like the San Joaquin Valley Air Pollution
Control District (SJVAPCD), California Air Resource Board (CARB), Cal EPA, and the
National Resources Defense Council(NRDC) rooting for the U.S EPAs approval, there are some

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organizations like Western States Trucking Association (WSTA) that are adamantly opposed to
any regulatory efforts involving diesel emission reductions. In fact, the WSTA, formerly known
as the California Construction Trucking Association (CCTA), filed a lawsuit against CARB in
2008 to oppose the CA Statewide Truck and Bus Regulation, which dictated that all heavy-duty
diesel engines had to be retrofitted or replace to comply with the particulate matter filters by
2010. The CCTA based their lawsuit on the grounds that it this regulation was unconstitutional
as stated by the Federal Aviation Administration Authorization Act (FAAA), which prohibits
any state or any political subdivision from enacting or enforcing any regulation related to the
price, route, or service of a motor carrier (CCTA (CDTOA) v. CARB-Sep 12). The CCTA
argued that the Truck and Bus Rule added unforeseen economic expenses that were costly and
economically damaging for businesses. Although in other states, the FAAAA argument has
overruled the court, in California this lawsuit was dismissed in 2012 under insufficient evidence
provided by the CCTA to prove that this rule was particularly damaging. Despite losing their
lawsuit, the WSTA is an active organization whose members are not limited to Californian
truckers, but have changed their name to obtain more supporters and have currently become one
of the biggest threat mounting opposition to the 2015 CA SIP.
Although the WSTA have some quite valid reasons for opposing the 2015 CA SIP, costbenefit-analysis have shown that the costs of pollution cleanup is relatively small compared to
the annual health care cost that non-attainment regions endure year after year. According to the
doctors from the Environment Defense Fund (EDF), the putting cost-effective controls on diesel
engines can significantly help protect our most vulnerable citizens, reduce health care costs,
and save up to 9,400 lives (from those affected by air pollution that die prematurely) between
2011 to 2015 (California Rules to Cut Diesel Truck Pollution Called Most Sweeping in U.S. ).

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In fact Figure 4, shows that retrofitting current diesel engines to comply with the regulation will
reduce diesel soot emissions by 85% and replacing engines with newer technology has the ability
to reduce smog-forming pollutants by 90%. Although retrofitting diesel engines may seem rather
expensive, it is a cost-effective

Figure 4: Diesel Particulate Filters

plan which will benefit all of
California past the proposed
years for attainment.
Similar plans, like the
2015 CA SIP, have been
developed to help non-attainment
areas comply with national
Figure 4: The Diesel Particulate Filter found in new diesel
engines has the potential of reducing smog-forming
pollutants by up to 90% compared to the current diesel
engines found in heavy-duty trucks manufactured before
2010.

standards, such is the case with

the Super Pollutant Emission
Reductions Act of 2015. The

Super Pollutant Emission Reduction Act of 2015 aims to help non-attainment areas through
grants, the areas are designated by U.S EPA and then are giving grants based on their eligibility
and need (Super Act of 2015). However this Act is nowhere near as elaborate or as specific as
the 2015 CA SIP, it relies on established agencies to improve their standards without much help
other than the funding EPA approves. The act would also become a national response to affected
areas, meaning that its budget will be somewhat insufficient to cover all areas. Furthermore, it
proposes the reduction of short-term pollutants, meaning it will potentially focus on reducing
pollutants that will bring the area to an attainment level quickly versus the long term effects that
the 2015 CA Sip has the potential of creating. Although this act also has the potential of

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improving the air quality in Fresno, its solution is not as effective to the same extent of the 2015
CA SIP because it focuses on areas in which Fresno and the San Joaquin Valley are not as
effected.
The 2015 CA SIP, although extremely lengthy in appearance and complicated in
implementation, currently proposes one of the best solution for Fresno and the San Joaquin
Valley in order to achieve the national air quality standards. It not only seeks to improve air
quality in the region but it is also a crucial step in protecting vulnerable demographics that are
affected by the current problem. Despite the fact that the 2015 CA SIP is costly and focused on
long-term solutions it has the potential of repairing years and years of damage, especially since it
targets the largest contributing source to the problem. Although like anything having to do with
politics, the 2015 CA SIP will without doubt have opposition it is imperative that this is passed
in order to start resolving Fresnos bad air quality problem, given that weather conditions and
topography will only continue to worsen the problem.

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Works Cited
Air Pollution: Where Does It Come From? Clean Air Primer. San Joaquin Valley Air Pollution
Control District. Web. 15 Oct. 2015
"California Rules to Cut Diesel Truck Pollution Called Most Sweeping in U.S." Environmental
Defense Fund.12 Dec. 2008. Web. 15 Nov 2015.
"Carl Moyer Memorial Air Quality Standards Attainment Program." Carl Moyer Memorial Air
Quality Standards Attainment Program. Web. 20 Nov. 2015.
"CCTA (CDTOA) v. CARB - Sep 2012 - Western States Trucking Association (WSTA)."
Western States Trucking Association WSTA. 13 Sept. 2012. Web. 20 Nov. 2015.
"Climate Change/Black Carbon." Diesel Technology Forum. Web. 15 Nov. 2015.
<http://www.dieselforum.org.>
Corey, Richard. "CARB Public Hearing Notice." 19 June 2015. Web. 1 Nov. 2015.
Fresno County Asthma Profiles. California Breathing. March 2015. Web. 19 Oct. 2015
"Goods Movement Emission Reduction Program." California Strategic Growth Plan: Bond
Accountability: Transportation. Web. 20 Nov. 2015.
Guidance for Assessing and Mitigating Air Quality Impacts. San Joaquin Valley Air Pollution
Control District. 19 March 2015. Web. 20. Oct. 2015
"Inversion Layer." Clean Air Primer. 1 Dec. 2006. Web. 1 Dec. 2015.
"Text of the SUPER Act of 2015." GovTrack.us. 22 Jan. 2015. Web. 05 Nov. 2015.
Velasco, Patricia. "ARB Review of San Joaquin Valley PM2.5 State Implementation Plan." 20
Apr. 2015. Web. 1 Nov. 2015.