United States Environmental Protection Agency

Air Division

Technical Support

For The

Placer County Air Pollution Control District 

Rule 503, Emission Statement 

Prepared by: Cynthia Allen

Reviewed by: Andrew Steckel

January 2012
-2-

AGENCY: Placer County Air Pollution Control District (PCAPCD)

SIP Approved Rule: Not Applicable

Superseded Submittals: None

Subject of this TSD: Rule 503, Emission Statement 

Submitted – December 7, 2010

Amended – August 10, 2010

BACKGROUND

Federal Clean Air Act (CAA) Section 182(a)(3)(B)(i) requires ozone 

nonattainment areas (regardless of classification) to require certified emission 

statement data from sources of volatile organic compounds (VOC) and oxides of 

nitrogen (NOx). Emission statements should be submitted by November 15, 1993 

and annually thereafter. CAA Section 182(a)(3)(B)(ii) allows states to waive the 

requirement for emission statements for classes or categories of sources with 

less than 25 tons per year (typ) of actual plant-wide NOx or VOC emissions if the 

State provides an inventory of emissions from the class or category based on the 

use of emission factors established by EPA or other methods acceptable to EPA. 

Emission Statements are intended to help the state report and analyze ambient 

air emissions. The CAA also requires states to periodically compile and report a 

comprehensive, accurate and current inventory of all air contaminant sources.

RULE SUMMARY

Rule 503 requires the owner or operator of any stationary source permitted by 

the District with actual or potential emissions over 10 tpy to provide an annual 

statement of actual emissions or operational data so that the District can 

calculate emissions. The emission statement must be in a format specified by 

the Air Pollution Control Officer (APCO) and must include the following

information: operational data necessary to compute actual emissions for the prior 

calendar year, information regarding diurnal or seasonal peaks in emissions, and 

certification by a responsible official that the statement is accurate. Failure to 

submit may result in the suspension of the source’s permit(s).

EPA EVALUATION

The following criteria were used to evaluate the submitted rule:
1. CAA Requirements: Section 182 (a)(3)(B) and EPA’s draft “Guidance on the 

Implementation of an Emission Statement Program,” July 1992. 

 

2. Enforceability: The Bluebook (Issues Relating to VOC Regulation Cutpoints, 

Deficiencies, and Deviations, EPA, May 25, 1988) and the Little Bluebook 

(Guidance Document for Correcting Common VOC & Other Rule 

Deficiencies, EPA Region 9, August 21, 2001) were used to help evaluate 

compliance with the CAA Section 110(a)(2)(A) requirement for enforceability. 

The submitted rule complies with the requirements found in CAA Section 

182(a)(3)(B). The rule will have no direct effect on air pollution emissions 

although it may help improve compliance and enforceability of emission control 

requirements in other PCAPCD rules.

The rule requires that the emission statements contain all of the information found 

in the District’s Renewal Information Request. The CAA does not provide 

formatting requirements or specify timing beyond that reports must be submitted 

annually, and deference is given to the State to assure that all information needed 

to meet Federal reporting requirements is requested. To ensure consistency and 

accuracy of reporting, however, we recommend further details be included within 

the rule as described in “Additional Recommendations for the Next Rule Revision” 

below.

The rule requirements are clear and enforceable consistent with CAA Section 

110(a)(2)(A).

ADDITIONAL RECOMMENDATIONS FOR THE NEXT RULE REVISION

The following revisions are not currently the basis for rule disapproval, but are 

recommended as improvements the next time the rule is revised.

 To ensure clarity and consistency in how emission estimates are 

generated, we recommend that future revisions to the rule include a list of 

minimum data elements required in emission statements as described in 

section 2.2.6, 2.27, and 2.28 of the guidance document “Guidance on the 

Implementation of an Emission Statement Program,” July 1992 or other 

details as required by federal reporting requirements.

EPA ACTION

EPA staff recommends approval of Placer County APCD Rule 503 under section 

110(k) as meeting the requirements of section 110(a) and Part D of the Clean Air 

Act, as amended in 1990. 

REFERENCES

1. Issues Relating to VOC Regulation, Cutpoints, Deficiencies, and Deviations 

(the “Blue Book”), U.S. EPA, OAQPS, May 25, 1988.
2. Requirements for Preparation, Adoption, and Submittal of Implementation 

Plans, U.S. EPA, 40 CFR Part 51.

3. State Implementation Plans for National Primary and Secondary Ambient 

Air Quality Standards, Section 110 of the Clean Air Act, and Plan 

Requirements for Nonattainment Areas, Title I, Part D of the Clean Air Act. 

4. EPA’s draft “Guidance on the Implementation of an Emission Statement 

Program,” Dated July 1992.