STAFF REPORT 

Rule 3.22 

Internal Combustion Engines 

Date of Release: February 26, 2009 

Schedule of Meetings

Rule 3.22 Workshop: April 16, 2009 

Public Hearing: June 1, 2009 

 
STAFF REPORT 

Stationary Internal Combustion Engines

Date of Release: February 26, 2009 

Scheduled Date of FRAQMD Adoption: June 1, 2009 

Feather River AQMD, 938 14th Street, 

Marysville, California 95901 

Contents Page 

Executive Summary.................................................................................................1 

1. Purpose...............................................................................................................1 

2. Background........................................................................................................1 

3. Legal Mandate ...................................................................................................2 

4. Proposed Rule Requirements.............................................................................3 

5. Socioeconomic Impact.......................................................................................4 

6. Effectiveness of Control Measures ....................................................................5

7. Estimated Cost Impact .......................................................................................9 

8. Environmental Review and Compliance .........................................................10 

9. Required Findings............................................................................................11 

 

........................................... 

Attachment A. Rule Analysis 

Attachment B. Public Notice 

Attachment C. Comments and Responses 
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Rule 3.22 STAFF REPORT

Executive Summary 

Feather River Air Quality Management District (District) is a Bi-County district that administers local, 

state and federal air quality management programs for Yuba and Sutter Counties. Under the provisions 

of the California Clean Air Act (CCAA) of 1988, Yuba County and the northern portion of Sutter County 

have been designated as “moderate” non-attainment areas for failing to meet the state ozone standard. 

The southern portion of Sutter County is designated as “serious” non-attainment for failing to meet the 

state ozone standard. Yuba and Sutter Counties are also designated “moderate” non-attainment for 

failing to meet the state particulate matter standard. 

Ozone is formed when volatile organic compounds (VOCs) react with nitrogen oxides (NOx) in the 

presence of sunlight, and is one component of “smog”. Ozone is a strong irritant that attacks the 

respiratory system, leading to damage of lung tissues. Exposure to ozone aggravates asthma, bronchitis 

and other respiratory diseases, as well as cardiovascular diseases. Reductions of NOx and VOCs are 

necessary to attain and maintain the state ambient air quality standard for ozone. 

Particulate matter consists of very fine liquid and solid particles suspended in the air. Particles smaller 

than 10 microns in size are known as PM10, while the very smallest particles less than 2.5 microns in size 

are known as PM2.5. Particulate matter becomes entrained in the air due to paved road dust, wood 

burning, motor vehicles, diesel engines, and other combustion sources. Reducing particulate matter air

pollution is one of the California’s highest public health priorities because it is linked to increased 

frequency and severity of asthma attacks, pneumonia and bronchitis, and even premature death in people

with pre-existing cardiac or respiratory disease. Reductions of PM10 and PM2.5 are necessary to attain

and maintain the state ambient air quality standards.

The 2003 Air Quality Attainment Plan requires the Northern Sacramento Valley Air Basin (NSVAB) to 

adopt rules and regulations deemed necessary to attain and maintain the state ambient air quality 

standard for criteria pollutants at the earliest practical date. Senate Bill 656 addressed multiple control 

measures that would help reduce the particulate matter concentrations in the air. Rule 3.22, Stationary 

Internal Combustion Engines has been developed to fulfill the commitment made by the District and to 

help attain the state ambient air quality standards for ozone and particulate matter. 

1.0 Purpose:

The purpose of Rule 3.22 is to limit emissions of nitrogen oxides (NOx), carbon monoxide (CO) and 

volatile organic compounds (VOCs) from stationary internal combustion engines with rated break 

horsepower greater than or equal to fifty (>50 hp). This rule would also bring about reductions in the

particulate matter emitted from the engines. 

2.0 Background: 

Stationary IC engines are typically used as either primary or backup engines to generate electricity or 

power pumps and compressors. IC engines are fueled by diesel, natural gas, propane (LPG), refinery fuel 

gas, digester gas, and landfill gas. Some final products of combustion include oxides of nitrogen (NOx), 

carbon monoxide (CO), volatile organic compounds (VOC), and fine particulate matter (PM-10), which 

are all discharged into the atmosphere. Oxides of nitrogen and volatile organic compounds are recognized 

as precursors to ground-level ozone formation, and reductions in NOx and VOC are necessary to attain 
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and maintain the state ambient air quality standard for ozone. Ozone can result in reduced lung function, 

increased respiratory symptoms, increased airway hyperactivity, and increased airway inflammation. 

Emissions of VOCs also react in the atmosphere to form PM10 and PM2.5. Inhalation of PM10 and 

PM2.5 deep into the lungs reduces human pulmonary function.

Staff proposed to adopt Rule 3.22 to achieve reasonable emission reductions from stationary internal 

combustion engines to help attain the state and federal ambient air quality standards for ozone and 

particulate matter. The proposed rule will also be consistent among the NSVAB Districts, where 

emission standards are based on the CARB’s Determination for Reasonable Available Control 

Technology (RACT) and Best Available Retrofit Control Technology (BARCT) for stationary internal 

combustion engines. 

3.0 Legal Mandate: 

State Mandates: Yuba County and the northern area of Sutter County is designated as “moderate” nonattainment for the state ozone standard. The southern area of Sutter County, also known as the 

Sacramento Federal Non-attainment Area (SFNA), is designated “serious” non-attainment for the state 

ozone standard. The California Clean Air Act (CCAA) requires areas designated as non-attainment for 

ozone to adopt control measures required in Section 40918 & 40919 of California Health and Safety Code

(CH&S). CH&S Code, Section 40918 requires the District to adopt a control measure that will use 

reasonable available control technology (RACT) for all existing stationary sources in the “moderate” nonattainment area. CH&S Code, Section 40919 requires the District to adopt a control measure that will use 

Best Available Retrofit Control Technology for all existing stationary sources in the “serious” nonattainment area. The CCAA also requires the District to develop a plan to achieve California’s ambient air 

quality standard by the earliest practical date (CH&S Code Section 40913). 

Yuba and Sutter Counties are also designated as “moderate” non-attainment for the state PM10 standard.

In 2003, the Legislature passed Senate Bill 656 to reduce public exposure to PM10 and PM2.5. The 

legislation requires the ARB, in consultation with local air pollution control and air quality management 

districts, to adopt a list of the most readily available, feasible, and cost effective control measures that 

could be implemented by air districts to reduce PM10 and PM2.5. Pursuant to SB 656, the Board of 

Directors of the Feather River Air Quality Management District passed and adopted the Particulate Matter 

Control Measure Implementation Schedule at a meeting on August 1, 2005. Rule 3.22 was included on 

this implementation schedule. Measures adopted as part of SB656 will complement and support those 

required for the State attainment plan as well as for State ozone plans. This will ensure continuing focus 

on PM reduction and progress towards attaining California’s more health protective standards. 

Federal Mandates:

In 2004, EPA designated the Sacramento region as one of the nation’s four worst 8-hour ozone 

nonattainment areas. This region, called the Sacramento Federal Nonattainment Area, includes all of 

Sacramento and Yolo counties and portions of Placer, El Dorado, Solano, and Sutter counties. Federal 

law and regulations set specific planning requirements for adopting and implementing a plan to meet 

reasonable further progress goals and demonstrate attainment of the 1997 federal ozone standard as 

expeditiously as practicable, but no later than our attainment deadline. This State Implementation Plan 

(SIP) contains a list of control measures which will help the area meet federal Clean Air Act planning

requirements for the 1997 health based standards for 8-hour ozone. Rule 3.22 was included on the list as a 

feasible control measure. 

All Feasible Measures Requirements: California Health and Safety Code Section 40914 requires the 

District’s plan to demonstrate that the plan includes “every feasible measure" to control emissions. 
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Accordingly, the District must adopt an effective control measures to limit NOx emissions from internal 

combustion engines. The District has evaluated the standards in the rule against similar requirements 

recently adopted by other districts. The District has determined that the standards are feasible and have 

been achieved in practice. 

4.0 Proposed Rule Requirements: 

4.1 Applicability 

Rule 3.22 applies to all internal combustion engines with rated break horsepower greater than or 

equal to fifty (>50 hp) used in industrial, institutional, and commercial operations that operate 

within the boundaries of the District. 

4.2 Standards 

All internal combustion engines shall not be operated above the emission limitations according to 

the area of designation and fuel type, as shown in Table 1 and 2. 

Table 1: North FRAQMD Emission Limits 

NOx 

(ppmv at 15% O2) 

VOC 

(ppmv at 15% O2)

CO 

(ppmv at 15% O2) 

Spark Ignited 

Rich Burn 90 250 4000 

Spark Ignited 

Lean Burn 150 750 4000 

Compression 

Ignited 600 750 4000 

Table 2: South FRAQMD Emission Limits 

NOx 

(ppmv at 15% O2) 

VOC 

(ppmv at 15% O2)

CO 

(ppmv at 15% O2) 

Spark Ignited 

Rich Burn 25 250 4000 

Spark Ignited 

Lean Burn 65 750 4000 

Compression 

Ignited 80 750 4000 
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4.3 Compliance Schedule 

The owner or operator of one or more stationary internal combustion engines subject to this rule 

shall choose one of the following compliance schedules: 

4.3.a For each engine to be permanently removed from service and replaced with an 

electric motor: 

(1) Submit a statement to the Air Pollution Control Officer identifying the engine 

to be removed no later than six months after District adoption of the rule; 

(2) Replace the engine with an electric motor no later three years after District 

adoption of the rule; 

4.3.b For all other engines subject to this determination: 

(1) Have all required applications for permits to construct submitted to the Air 

Pollution Control Officer no later than one year after District adoption of the 

rule; 

(2) Have each engine demonstrate compliance with the emission limits no later 

than two years after District adoption of the rule;

4.4 Monitoring and Recordkeeping 

The owner or operator of one or more stationary internal combustion engines subject to this rule 

shall meet the following requirements: 

4.4.a To demonstrate on-going compliance, a unit will be source tested once every five 

years. During any year in which a source test is not performed, a portable analyzer shall be 

used to take emission readings to verify compliance with the emission limits. 

4.4.b All emission readings shall be taken at an engine’s actual peak load and under the 

engine’s typical duty cycle. The analyzer shall be calibrated, maintained and operated in 

accordance with the manufacturer’s specifications and recommendations or a protocol 

approved by the Air Pollution Control Officer. An instrument reading in excess of the 

emission compliance values shall not be considered a violation, so long as the engine is 

brought into compliance within 15 days of the initial out of compliance reading.

4.4.c All records shall be maintained for at least five years and made available for inspection 

by the Air Pollution Control Officer or the Officer's designee.

5.0 Socioeconomic Impact: 

Yuba and Sutter counties have a combined population less than 500,000 persons. The Required 

Assessment in subsection (d) of the California Health and Safety Code (Section 40728.5) states, “This 

section does not apply to any district with a population of less than 500,000 persons.” A socioeconomic 

impact analysis is not required. 
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6.0 Effectiveness of Control Measures: 

The reduction of NOx emissions from process equipment, such as internal combustion engines, is mainly 

accomplished through pre-combustion modifications and/or post-combustion exhaust controls. The 

application of a specific technique will depend on the type of engine, the characteristic of its primary fuel, 

and method of firing. Table 3 presents a summary of these technologies and other feasible options that

includes affected engine type, approximate effectiveness over uncontrolled emissions, cost estimates, and 

a general description. 

6.1 Pre-combustion Modifications 

Pre-combustion modifications affect the way fuel is combusted or “burned.” Some of these 

techniques include changing the air to fuel ratio, reducing the peak combustion temperature, 

shortening the residence time at high temperatures, or adjusting the ignition or injection timing. 

1. Air/Fuel Ratio Changes

Stoichiometry is achieved when the air/fuel ratio is such that all the fuel can be fully oxidized 

with no residual oxygen remaining. NOx formation is highest when the air/fuel ratio is slightly on 

the lean side of stoichiometric. At this point, both CO and VOC are relatively low. Adjusting the 

air/fuel ratio toward either leaner or richer mixtures from the peak NOx formation air/fuel ratio 

will reduce NOx formation. 

In the case of leaner mixtures, the excess air acts as a heat sink, reducing peak temperatures, 

which results in reduced NOx formation. The excess air also allows more oxygen to come into 

contact with the fuel, which promotes complete combustion and reduces VOC and CO emissions. 

As the mixture continues to be leaned out, the reduced temperatures may result in a slight 

increase in CO and VOC emissions. Operating the engine on the lean side of the NOx formation 

peak is often preferred over operating rich because of increased fuel efficiencies associated with 

lean operation. However, use of very lean air/fuel ratios may result in ignition problems. For this 

reason, techniques designed to improve ignition are often combined with lean air/fuel ratios to 

control NOx emissions and avoid increases in VOC emissions. 

NOx formation will also decrease if the mixture is richened from the peak NOx air/fuel ratio. 

However, a mixture richer than stoichiometric will result in incomplete combustion. Nearly all 

the oxygen will then combine with the fuel and emissions of CO and VOC will increase. 

2. Turbocharging and Aftercooling

Turbochargers compress the intake air of an engine before this air enters the combustion 

chamber. Due to compression, the temperature of this air is increased. This tends to increase peak 

temperatures, which increases the formation of NOx. However, the heat sink effect of the 

additional air in the cylinder, combined with the increased engine efficiency from turbocharging 

or supercharging, generally results in a minor overall decrease in NOx emissions per unit of 

power output. On the other hand, turbocharging can significantly increase the maximum power 

rating of an engine, which increases the maximum mass emissions rate for NOx. Due to the high 

density of oxygen in the combustion chamber, turbocharging makes the combustion process more 

effective, which tends to reduce emissions of CO and VOC. 
- 6 - 

On turbocharged engines, the intake air temperature can be reduced by aftercooling (also known 

as intercooling or charge air cooling). An aftercooler consists of a heat exchanger located 

between the turbocharger and combustion chamber. The heat exchanger reduces the temperature 

of the intake air after it has been compressed by the turbocharger. Cooling the intake air reduces 

peak combustion temperatures, and thereby reduces NOx emissions. The cooling medium can be 

water, either from the radiator or from a source outside of the engine, or the cooling medium can 

be ambient air. The cooling effects of the aftercooler increases the density of the intake air, which 

results in a leaner air/fuel mixture in SI engines if no additional fuel is introduced. For engines 

already using lean air/fuel mixtures, this leaner mixture will lower NOx emissions further. 

6.2 Post-combustion Exhaust Control 

Post combustion controls generally consist of catalysts or filters that act on the engine exhaust to 

reduce emissions. Post combustion controls also include the introduction of agents or other 

substances that act on the exhaust to reduce emissions, with or without the assistance of catalysts 

or filters. 

1. Non-Selective Catalytic Reduction (NSCR)

The NSCR catalyst promotes the chemical reduction of NOx in the presence of CO and VOC to 

produce oxygen and nitrogen. The 3-way NSCR catalyst also contains materials that promote the 

oxidation of VOC and CO to form carbon dioxide and water vapor. To control NOx, CO, and 

VOC simultaneously, 3-way catalysts must operate in a narrow air/fuel ratio band (15.9 to 16.1 

for natural gas-fired engines) that is close to stoichiometric. An electronic controller, which 

includes an oxygen sensor and feedback mechanism, is often necessary to maintain the air/fuel 

ratio in this narrow band. 

When applying NSCR to an engine, care must be taken to ensure that the sulfur content of the 

fuel gas is not excessive. The sulfur content of pipeline-quality natural gas and LPG is very low, 

but some oil field gases and waste gases can contain high concentrations. Sulfur tends to collect 

on the catalyst, which causes deactivation. This is generally not a permanent condition, and can 

be reversed by introducing higher temperature exhaust into the catalyst or simply by heating the 

catalyst. 

The total installed cost of an NSCR system on an existing engine varies with the size of the 

engine. For an 80 horsepower engine, total costs for installation may range from $5,000 to 

$11,000. For an 1,100 horsepower engine, installed costs of $20,000 to $25,000 are typical. 

2. Selective Non-Catalytic Reduction (SNCR)

SNCR reduces NOx by injecting ammonia or urea into the exhaust gas. The injected ammonia or 

urea reacts with the nitrogen oxides to produce nitrogen gas and water vapor. A drawback of 

SNCR is that it is highly dependent on temperature, which must be between the 1400o

F to 2000oF 

range. If the temperature is below 1600oF, chemical enhancers such as hydrogen may be required 

to help the reaction. If the temperature is above 2000oF, the ammonia or urea tends to react with 

any available oxygen to form NO. 

With SNCR, it is very important to control the excess un-reacted ammonia. The excess ammonia 

could react with other combustion by-products and form ammonia salts or may pass through the 

system and into the atmosphere. This is known as an ammonia slip and it is sometimes visible in 

the plume from the stack. Due its environmental impact, SNCR systems are restricted to not emit 
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ammonia in excess of 20 ppmv at dry stack conditions adjusted to 3% oxygen into the 

atmosphere. 

3. Selective Catalytic Reduction (SCR)

A Selective Catalytic Reduction unit is another post-combustion control measure and is operated 

similar to a SNCR. However, instead of injecting into a specific temperature zone, SCR injects 

ammonia into the flue gas over a catalyst bed. The catalyst bed allows the reaction to reduce NOx 

at a temperature range from 500oF to 850oF. Similar to SNCR, the ammonia slip must be 

regulated. 

6.3 Engine Replacement 

Rather than applying controls to the existing engine, another viable option it is to replace it with 

either a new, low emissions engine or an electric motor. However, in remote locations or where 

electrical infrastructure is inadequate, the costs of electrical power transportation and 

conditioning may be excessive. 
- 8 - 

Table 3: Summary of NOx Emission Control Technologies for Stationary IC Engines 

Control 

Technology 

Engine 

Types Effectiveness Capital Costs Description 

Non-Selective 

Catalytic Reduction 

(NSCR) 

Rich Burn 

Engines 

NOx: >98% 

CO: >97% 

HC: >80% 

$50-

200/bhp

Exhaust Control: Post combustion oxidation of HC & C

catalyst (usually a noble metal like platinum, rhodium, oCO are converted to CO2 and water, while the NOx is re

Selective Catalytic 

Reduction (SCR) 

Lean Burn 

Engines 

NOx: >95% 

CO: >97% 

HC: >80% 

$135-

510/bhp

Exhaust Control: Ammonia or urea injected in the exha

HC & CO are converted to CO2 and water, while the NO

Post Combustion 

Oxidation & 

Selective NonCatalytic Reduction 

CI, Lean Burn, 

and Rich Burn 

Engines 

NOx: >90% 

PM: 60% 

CO: <10 ppm 

$30-

155/bhp

Exhaust Control: 

• Non-Catalytic Oxidation of HC, PM, CO • Exhaust heated to 1,400 to 1,550 °F through fue

• Urea injected to reduce NOx • Ammonia Slip (2 ppm) 

SCR with Diesel 

Particulate Filtration CI Engines NOx: 95% PM: 89% $180- 620/bhp Exhaust Control: • Aqueous urea injected • Ammonia slip: 4.4 ppm with 30 ppm spikes 

Lean + Derating Rich and Lean Burn Engines NOx: >80% n/a

Combustion Control: Increase the air-to-fuel ratio towa

decrease the cylinder pressures and temperature which of an engine. The lower pressure and temperature reduc

increase HC & CO. 

Pre-Stratified 

Charge 

Rich and Lean 

Burn Engines NOx: >80% $1250- 1825/bhp Combustion Control: Small amounts of air are introduc

create sequential fuel-rich and fuel-lean zones. This pro

ignition zone and rapid flame cooling in the fuel-lean zon

Low-Emission 

Combustion 

Rich and Lean 

Burn Engines NOx: >80% $285/bhp

Combustion Control: Lean Burn combined with: 

• ignition system improvement, • turbocharging, aftercooling • air/fuel ratio controller 

Engine 

Replacement 

CI, Lean Burn, 

and Rich Burn 

Engines 

60-100% Variable 

For replacement with an electric motor, emissions are re

IC engine location. For replacement with a newer engine

drastically. 
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7.0 Estimated Cost Impact: 

The proposed Rule 3.22 will require all units subject to this rule to meet the associated emissions 

standards. Some sources may need to install additional equipment such as operational tracking devices 

and/or emission control devices to be exempt from the emission standards. The proposed rule will also

require compliance testing to show compliance with the required emission standards. A summary of the 

estimated cost for equipment and testing is shown below in Table 4. 

Table 4: Summary of Estimated Cost 

Capital Investment Cost (dollars) 

Non-resettable Hour Meter 

Fuel Flow Meter 

Equipment Retrofit 

 Air/Fuel Ratio & Engine Adjustments 

 Turbocharging/Aftercooling 

 NSCR & Air/Fuel Ratio Controller 

 SCR 

Portable Analyzer 

Replace Unit 

$400 

$1,500 

$1,000 

$5,000 to $40,000 

$5,000 to $25,000 

$90,000 

$4,000 to $8,000 

Variable 

Compliance Cost (dollars)

Initial Compliance: Source Test 

On-going Compliance Program 

$2,000-$4,000/unit 

$500/unit 

After one year of the date of adoption of the proposed rule, all internal combustion engines which need to 

be modified for the exemption of this rule shall install either a non-resettable hour meter or a fuel flow 

totalizing meter to track the annual usage of each unit. The District anticipates most owners or operators 

will chose to install a non-resettable hour meter, which will cost about $400. The majority of the engines 

in the District already have these installed, so no further work will be required. 

For each unit to be in compliance with rule 3.22, the facility must show that the unit meets the emissions 

requirement. Most units can achieve the emission standards by retrofitting the unit with a NSCR catalytic 

converter, which ranges from $5,000 to $25,000, or simply by tuning the combustion controls, which 

costs around $1,000. 

It is expected that around 40% of the engines in the District will need some sort of modification to satisfy 

the emissions limit. The majority of the engines which need to be phased out are the older lean burn 

engines. Adding emission control devices to these engines tend to be expensive. It is expected that the 

majority of these lean burn engines will be replaced with rich burn engines with NSCR catalytic 

converters. 

To show initial compliance, the proposed rule requires the facility to perform a source test on the engine 

or provide results verifying the engine meets the emissions limits. The cost of a source test is about
- 10 - 

$2,000-$4,000 per engine using a reference method such as ARB Method 100. Costs are less if multiple 

engines are tested at the same time. If the engine is already certified to the emission limits, there won’t be 

any additional costs to achieve initial compliance. It is expected that around 80% of the engines will need 

to be source tested. 

To show ongoing compliance, a hand-held portable NOx analyzer will be needed. The cost of an analyzer 

ranges from $4,000 to $8,000. Many engine operators who perform their own maintenance and maintain 

several engines already use portable analyzers. Smaller operators generally contract out engine 

maintenance, and nearly all maintenance contractors already have analyzers. The expected cost of the ongoing compliance program is around $500 per engine per year due to labor costs. 

There are currently around 76 stationary prime internal combustion engines larger than 50 bhp located 

within the District, which are summarized in Table 5. If left uncontrolled, these engines generally pollute 

between 3 to 10 tons per year of NOx depending on the size of the engine. This corresponds to around 

360 tons of NOx emissions per year within the District. However, about 60% of the engines already have

NSCR catalytic converters. After the control technologies are implemented for the remaining engines, the 

engines are expected to pollute at least 70% less than their current emission levels. This would decrease 

NOx emissions within the District by 100 tons per year. 

360 tons/yr * 40% needing modifications * 70% reduction = 100 ton/yr less pollution 

Table 5: Summary of Prime Stationary Engines over 50 hp in Yuba and Sutter Counties 

Fuel Number of Engines 

Spark Ignited 

Rich Burn 44 

Spark Ignited 

Lean Burn 21 

Compression Ignited 11 

Total 76 

8.0 Environmental Review and Compliance: 

 

The adoption of rule 3.22 is categorically exempt from the California Environmental Quality Act (CEQA)

under Sections 15307 and 15308 of the State CEQA Guidelines and no exceptions to these exemptions 

apply. This exemption is allowed when the rule will help improve air quality in Yuba and Sutter County. 

California Public Resources Code (Section 21159) requires an environmental analysis of the reasonably 

foreseeable methods of compliance. The District has concluded that no reasonably foreseeable adverse 

environmental impacts will be caused by adoption of the proposed rule.
- 11 - 

9.0 Required Findings:

The California Health and Safety Code, Division 26, Air Resources, requires local Districts to comply 

with a rule adoption protocol as set forth in Section 40727 of the Code. This section has been revised 

through legislative mandate to contain 6 findings that the District must make when developing, amending, 

or repealing a rule. These findings and their definitions are listed in the following table. 

Table 6: Required Findings

FINDING DEFINITION REFERENCE

Authority A district shall adopt rules and regulations 

and do such acts as may be necessary or 

proper to execute the powers and duties 

granted to, and imposed upon, the district by 

this division and other statutory provisions 

California Health and Safety Code, Sections 

40000, 40001, and 40702 are provisions of 

law that provide air districts with the 

authority to adopt these proposed rules. 

Necessity The District has demonstrated that a need 

for the rule, or for rule amendment or 

repeal. 

It is necessary for districts to adopt these 

amendments to comply with state law and to 

ensure consistency with neighboring air 

districts. 

Clarity The rule is written or displayed so that its 

meaning can easily be understood by the 

persons directly affected by it 

There is no indication, at this time, that the 

proposed rules are written in such a manner 

that it cannot be easily understood by 

persons affected by the rule. 

Consistency This rule is in harmony with, and not in 

conflict with or contradictory to, existing 

statutes, court decisions, or State or federal 

regulations. 

These rules are consistent with applicable 

statutory requirements. 

NonDuplication The rule does not impose the same 

requirements as an existing State or federal 

regulation, unless the District finds that the 

requirements are necessary and proper to 

execute the powers and duties granted to, 

and imposed upon, the district 

The proposed rule does not impose 

requirements that duplicate existing laws or 

regulations. 

Reference Any statute, court decision, or other 

provision of law that the district 

implements, interprets, or makes specific by 

adopting, amending, or repealing a 

regulation. 

The proposed rule has been developed to 

meet the requirements of the 2003 State 

Implementation Plan. 
ATTACHMENT A 

Rule Analysis
ATTACHMENT B 

Public Notice
ATTACHMENT C 

Comments and Responses