Indirect Source Rules:

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Indirect Source Rules

• Cleaning Air in California and Beyond

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Californias Failing Air

• Home of two of the most polluted regions in the
  country
• 90 of states residents exposed to unhealthful
  air each year
• Mobile sources account for two-thirds of the
  pollution
• Growing dependence on vehicles reduces air
  quality gains

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A Solution to Growth-related Pollution Indirect
Source Rule

• Boldly recognizes what creates pollution growth
• Links air quality and land use decisions
• Provides incentives for builders to think and act
  green

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ISR Beginnings

• EPA initiated the idea
• Developers pushed back
• Limited local and state efforts evolved
• Colusa and Butte County Air Districts
• Oregon and Connecticut
• Methodology improves
• San Joaquin Valley begins new era

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ISR Common Characteristics

• Limit indirect emissions from developments by
  addressing
• The traffic linked to the new/modified
  development
• Project type (parking lots, highways)
• Energy demand from homes and businesses
• The pollution from construction (including
  equipment)
• Achieved by
• Promoting emission-reduction measures
• Allowing a fee mechanism for pollution not
  mitigated onsite

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ISR Benefits

• Long-term strategy for air quality
• Preserve open space and farm land
• Revitalize existing communities
• Increase travel and housing choices
• Reduced congestion
• Improve affordable housing
• opportunities
• Adaptable to any community

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Case StudyThe San Joaquin Valley

• Comprised of 8 counties

• The Nations Salad Bowl

• Oil and gas projects

• Home to over 3.2 million residents

• Largest cities are Fresno, Bakersfield, Modesto,
  and Stockton

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The San Joaquin ValleyPrimed for Pollution

• Environmental and geographic factors
• Diverse pollution sources
• Fast-growing region with unplanned development
• Increases in vehicle miles traveled

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The San Joaquin ValleyAir and Health

• EPA Many cities and counties in the SJV are the
  most polluted in the U.S.
• 1 in 6 children in Fresno has asthma
• 12,000 residents hospitalized for asthma each
  year
• 460 deaths a year

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The San Joaquin ValleyPath to an ISR

• Ozone and PM State Implementation Plans (SIPs)
• Legislative mandate
• Some developers desire
• Rules 9510 and 3180, adopted December 2005

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The San Joaquin Valley ISRThree Elements

• Covered projects and pollutants
• Measuring pollution reductions
• Achieving reductions

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The San Joaquin Valley ISRCovered Projects and
Pollutants

• Residential, commercial, and industrial
• Based on project size and type (i.e. at least 50
  residential units, 2000 sq. ft. commercial, etc.)
• Does not affect small, reconstruction, or
  expansion projects
• Mitigates NOx and PM10
• Construction equipment
• Operational 33 NOx and 50 PM10 over 10 years

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The San Joaquin Valley ISRMeasuring Pollution
Reductions

• Computer-generated models
• URBEMIS
• http//www.valleyair.org
• Project specific

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The San Joaquin Valley ISRAchieving Reductions

• Onsite reduction measures
• Mitigation fee for offsite reductions

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The San Joaquin Valley ISRCurrent Status

• Developers have been applying
• June 2006 lawsuit
• Use of fees uncertain
• Other districts considering ISR approach

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The Future ofIndirect Source Rules

• Address additional pollutants
• Strive for 100 mitigation
• Address all developments
• (small, old, and new)
• Set realistic timelines

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More Info

• San Joaquin Valley Air Pollution Control
  District
• http//www.valleyair.org
• Environmental Defense report on ISR
• http//www.environmentaldefense.org/documents/4733
  _IncentivesHealthyCommunities.pdf
• Kathryn Phillips, Manager, Clean Air for Life
  Project at Environmental Defense
• kphillips_at_environmentaldefense.org