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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. As directed by the California Health and Safety Code (CH&SC), ARB’s role is to oversee the Carl Moyer Program by managing program funds, developing and maintaining guidelines, and determining cost-effectiveness methodologies. 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 guidelines include robust administrative requirements to ensure that emission reductions are enforceable and are achieved throughout the life of a project. The District has used the Carl Moyer Program Guidelines to develop the practices that are currently in place to ensure all emissions are surplus, quantifiable, enforceable, and permanent, and that emission reductions are SIP-creditable.

Carl Moyer Guidelines:

The following is a summary of how Carl Moyer Guidelines ensure emissions reductions are SIP-creditable.

The Carl Moyer Program Guidelines ensure that projects are surplus to regulations by only allowing projects to be selected that are not required by any federal, State or local regulation, memorandum of agreement/understanding with a regulatory agency, settlement agreement, mitigation requirement, or other legal mandate. For example, the guidelines have accounted for each adopted regulation to determine the compliance dates of any affected engines and emission benefits claimed by each regulation have been determined. Minimum project lives are established in each component to ensure that the program does not fund actions taken to comply with regulatory deadlines. The minimum project life requirement also ensures the overall cost-effectiveness of the program and that the emission reductions are real for the life of the project. The below summary provides more detail about how the Carl Moyer Program Guidelines ensure that the SIP-creditability integrity criteria of “Surplus” is fulfilled:
  • Requirement that emission reductions generated by incentive programs are not required by other regulation
    • (Moyer Guidelines Chapter 2, Project Criteria A, H, I, MM).
  • Protocols for quantifying maximum project life and maximum emission reductions which account for upcoming regulatory deadlines for a given source category
    • (Moyer Guidelines Chapter 2, Project Criteria B, I and MM).
  • Assurance that baseline equipment was in use
    • (Moyer Guidelines Chapter 3, Section Z.6(B) and AA.2.).
  • Assurance that new/upgraded equipment is not already accounted for in future-year inventories underlying a SIP attainment demonstration by natural fleet turnover, finite equipment life or incentives
    • The definition of surplus in the Moyer guidelines requires that the emission reductions achieved are above and beyond those required under existing regulations that are incorporated into a SIP. As part of the SIP development process, ARB reviews the Moyer project mix to ensure that the amount of emission reductions credited to program are not included in the future year inventories specific to each individual attainment demonstration.
  • Procedures that ensure that old equipment was used in the geographic area of interest
    • (Moyer Guidelines, Chapter 2, Section S and Chapter 3, Section Z.6.(B)).

The District evaluates the potential reductions that would be achieved by replacing the old equipment with the new equipment using the established calculation methodologies and emissions factors in the program guidelines. The calculation methodology, including calculation formulas, assumptions, emission factors and sample calculations are part of the Carl Moyer Program Guidelines and have been approved through a public process. To ensure that real, quantifiable emission reductions are achieved over the life of a project, the program guidelines require that emission control technologies be certified or verified by ARB (certification or verification by the EPA or International Maritime Organization may be allowed for some source categories for which ARB does not have a certification or verification program). The below summary provides more detail about how the Carl Moyer Program Guidelines ensure that the SIP-creditability integrity criteria of “Quantifiable” is fulfilled:
  • Emissions data needed to calculate emission reductions must be publicly available current and accurate. This should include appropriate emission factors, load factors, and other conversion factors.
    • Moyer Guidelines, Appendix D (Publicly Available) and Chapter 1, Section E.7 (Allows ARB Executive Officer to modify the Guidelines under a public process, to keep them effective and up-to-date.)
  • Guidelines include necessary formulas and instructions to calculate emissions based on above data, and explicit instructions to ensure appropriate data are used in calculations
    • Moyer Guidelines, Appendix C (contains formulas and instructions)
    • Moyer Guidelines, Supplemental document, “Sample Calculations” (contains formulas and instructions)
    • Requirement Moyer Guidelines, Appendix C, Section B.5, and Supplemental document, “Sample Calculations” (contains explicit instructions regarding inputs)
  • Requirement to provide activity data sufficient to determine actual emission reductions.
    • Moyer Guidelines, Chapter 3, Section Z.6.(B)
  • Requirement to demonstrate the percentage of emission reductions that occur in the geographic area of interest, and are therefore SIP creditable
    • Moyer Guidelines, Section S.
    • Moyer Guidelines, Section Z.6.(B)
  • Requirement to periodically audit completed projects to verify emission reduction projections are fulfilled
    • Moyer Guidelines Chapter 2, Sections Z.10.
    • Moyer Guidelines Chapter 3, Sections EE.

Emission reductions and other required actions are enforceable if: they are independently verifiable; program violations and those liable are defined; information needed to determine emission reductions is available to the public; and they are practicably enforceable in accordance with other EPA guidance on practicable enforceability. The below summary provides more detail about how the Carl Moyer Program Guidelines ensure that the SIP-creditability integrity criteria of “Enforceable” is fulfilled:
  • Require grantees to provide all necessary recordkeeping and reporting needed to verify emissions reductions
    • Moyer Guidelines, Chapter 3, Section Z.9 and DD
  • Require inspections to ensure incentive program information is consistent with actual operating equipment
    • Moyer Guidelines Chapter 3, Sections AA and BB
  • Identify liable parties and liability associated with contract noncompliance
    • Moyer Guidelines Chapter 3, Section Z.11.

To ensure that the SIP-creditable emissions reductions are permanent, actions such as pre-inspections and post inspections of the new equipment and verification that the baseline equipment has been destroyed through the required process as described in the program guidelines are performed. The below summary provides more detail about how the Carl Moyer Program Guidelines ensure that the SIP-creditability integrity criteria of “Permanent” is fulfilled:
  • Data needed to determine and track location of activity
    • Moyer Guidelines, Chapter 3, Section DD
  • Provisions for ensuring that the project was completed, including the verification of disposition of baseline equipment.
    • Moyer Guidelines Chapter 3, Sections AA and BB