SIP-Creditability of Incentive-Based Emission Reductions
When given State Implementation Plan (SIP) credit, incentive-based emission reductions can be used to complement regulatory-based emission reductions to assist meeting federal Clean Air Act (CAA) requirements. District Rule 9610 (State Implementation Plan Credit for Emission Reductions Generated through Incentive Programs) establishes a process through which incentive-based emission reductions can receive federal SIP credit. For incentive-based emission reductions to receive SIP-credit, the District must demonstrate that the emission reductions are Surplus, Quantifiable, Enforceable, and Permanent.
The following is a brief discussion of each of these elements as applicable to the District and incentive-based emission reductions.
Surplus
The District funds incentive projects based on incentive program guidelines that ensure that the resulting emission reductions are not otherwise required by any federal, state, or local regulation or other legal mandate. The emission reductions must also be in excess of the SIP baseline emission inventories underlying a SIP demonstration; meaning the base year, attainment year, and interim year emissions inventories as reported in a SIP that serve as a primary starting point for modeling and other SIP analyses.
Quantifiable
The District evaluates the potential reductions that would be achieved by replacing the old equipment with the new equipment using the established calculation methods and emissions factors in the appropriate program guidelines. To be quantifiable, emission reductions must be reliably determined and replicated through the use of well-established emission factors and calculation methodologies, as outlined in applicable incentive program guidelines. Using well-established emission factors and calculation methodologies ensure that the emission reductions can be replicated.
Enforceable
Emission reductions are enforceable if the incentive programs include the following provisions:
- The emission reductions must be independently and practicably verifiable for the duration of the project life through inspections, monitoring, and/or other mechanisms;
- Incentive program violations are defined through legally binding contracts, including identifying party or parties responsible for ensuring that emission reductions are achieved;
- Grantees are obligated to provide all records needed to demonstrate that emission reductions are achieved; and
- The public has access to all emission-related information for reductions claimed in the annual demonstration report.
Permanent
For purposes of SIP-creditability of incentive-based emission reductions, permanent is defined as permanent for the lifetime of the project. Permanence is ensured by actions taken to physically destroy or permanently disable, existing or baseline equipment, practices, or vehicles.
Mobile Sources
A large portion of the projects that are currently being funded are from mobile sources. These projects provide a unique challenge in that they may
operate only a percentage of time within the San Joaquin Valley. To ensure that SIP-creditable emissions reductions are only reported for the amount occurring in the San Joaquin Valley, the District requires that percent use in the District is reported at the time an application for funding is submitted. This information is also reported by the grantee each year during the project life through the annual Usage Report Surveys that every grantee is contractually required to complete and submit to the District.
Each program guideline addresses California operation within it’s specific methodology but percent use in the San Joaquin Valley is not adjusted for within the program guideline
methodologies. The District uses the percent use in the San Joaquin Valley reported by the grantee to adjust the total emissions reductions for each project prior to reporting SIP-creditable emissions reductions with Rule 9610. The formula for adjusting for percent use in the San Joaquin Valley is as follows:
Total Lifetime NOx Reduced (tons) * (Percent Operation in SJV/100) = NOx
Lifetime Reduced Adjusted Percent Operation (tons)
(5.59 tons/life) * (90%/100) = 5.03 tons
The formula is repeated for each pollutant being reported.
Incentive Program Guidelines
Carl Moyer Memorial Air Quality Standards Attainment Program Guidelines
The Carl Moyer Memorial Air Quality Standards Attainment Program (Carl Moyer Program) has been successfully implemented through the cooperative efforts of the California Air Resources Board (ARB) and air districts in California. Air districts use the Carl Moyer Program Guidelines to select, fund, and monitor projects in their jurisdiction by providing grants to public and private entities for the incremental cost of cleaner-than-required engines and/or equipment. The Carl Moyer Program Guidelines are available
here.
Proposition 1B Goods Movement Guidelines
Proposition 1B Goods Movement Guidelines were developed by ARB in consultation with stakeholders, including: air districts, metropolitan planning organizations, port authorities, shipping lines, railroad companies, trucking companies, harbor craft owners, freight distributors, terminal operators, local port community advisory groups, community interest groups, and airports. The guidelines include robust administrative requirements to ensure that emission reductions are surplus, quantifiable, enforceable, and permanent, and are available
here.
United States Department of Agriculture Natural Resource Conservation Service Combustion System
Improvement of Mobile Engines Guidelines
The United States Department of Agriculture (USDA) Natural Resource Conservation Service (NRCS) Combustion System Improvement of Mobile Engines Guidelines (Guidelines) implements robust administrative requirements for incentive projects based on those in the Carl Moyer Program Guidelines to ensure that emission reductions are surplus, quantifiable, enforceable, and permanent. The NRCS Combustion System Improvement of Mobile Engines Guidelines are available
here.
Terminology
Each program guideline varies in the use of terms for calculation methodolgies and project information. The following table identifies the variations between Rule 9610 terminology and the program guideline terminology.
| Rule 9610 |
Prop 1B |
Moyer |
NRCS |
Description |
| Project Identification |
Project Name |
Project Identification |
Project Identification |
Unique identification number given to a project by the implementing agency |
| Project Type |
Project Option |
Component, Component Option, and Primary Function |
Primary Function |
Describes the type of project and equipment being funded |
| Old Engine Year |
Engine Model Year |
Model Year |
Engine Year (baseline) |
Manufacturers model year of the old engine |
| Annual Miles |
CA VMT |
Miles Traveled |
N/A |
Miles travel per year for on-road vehicles |
| New GVWR |
GVWR |
GVWR |
N/A |
Gross Vehicle Weight Rating applicable to on-road vehicles only |
| Cost New Equipment/ Vehicle |
Total Project Cost ($) |
Cost of Reduced Technology |
Cost of New Engine or Equipment |
The total amount of money to purchase the new replacement vehicle, engine or equipment. Does not account for amount of grant funding. |
| Funding Amount |
Prop 1B Investment |
Funding Amount |
Payment |
Amount of grant money provided to implement incentive project. |
Previously Submitted Annual Demonstration Reports
The District’s annual demonstration report submitted to EPA and ARB serves as the reporting mechanism to claim credit in the SIP for incentive-based emission reductions in the Valley that are surplus, quantifiable, enforceable, and permanent. The draft annual demonstration report is made available to the public and presented to the District Governing Board prior to submittal to EPA and ARB no later than August 31 of each year.
The annual demonstration report provides a description of program guidelines used and how each ensures emission reductions are SIP-creditable, accounting of emission reductions achieved through implemented incentive projects, provides a summary of SIP commitments for which SIP-creditable emission reductions will be used to satisfy; provides project specific information, summaries of District project
monitoring and enforcement activities; and a
retrospective evaluation of the District’s incentive program performance with recommendations for improvements as appropriate.
2023 Annual Demonstration Report
2023 Annual Demonstration Report Data Sheet
2022 Annual Demonstration Report
2022 Annual Demonstration Report Data Sheet
2021 Annual Demonstration Report
2021 Annual Demonstration Report Data Sheet
2020 Annual Demonstration Report
2020 Annual Demonstration Report Data Sheet
2019 Annual Demonstration Report
2019 Annual Demonstration Report Data Sheet
2018 Annual Demonstration Report
2018 Annual Demonstration Report Data Sheet
2017 Annual Demonstration Report
2017 Annual Demonstration Report Data Sheet
2016 Annual Demonstration Report
2016 Annual Demonstration Report Data Sheet
2015 Annual Demonstration Report
2015 Annual Demonstration Report Data Sheet
2014 Annual Demonstration Report
2014 Annual Demonstration Report Data Sheet
2013 Annual Demonstration Report
2013 Annual Demonstration Report Data Sheet
Additional Resources
District Rule 9610
Final Staff Report with Appendices for Rule 9610
District Grant and Incentive Programs
TSD Project List
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