Sacramento Metropolitan Air Quality Management District

Rule 203 – Prevention of Significant Deterioration (PSD)

State Implementation Plan Equivalency Determination

January 28, 2011

Executive Summary

In 2002, the United States Environmental Protection Agency (EPA) approved modifications to 

the federal Prevention of Significant Deterioration (PSD) regulations (PSD Reform)1. Each state 

is required to amend its regulations to conform to the new federal program. If the state program 

deviates from the federal provisions, it must perform an equivalency analysis demonstrating its 

program is at least as stringent as the federal program2. 

In response to the EPA Reform effort, California enacted Senate Bill 288 (SB288) Protect 

California Air Act of 2003. SB288 prohibits districts from making rule changes that would 

weaken the permitting rules that were approved in the State Implementation Plan (SIP) or 

submitted for approval before December 30, 2002. For the District, the operative rule is the 

1991 version of Rule 203,3 which was submitted to EPA for inclusion in the SIP on November 7, 

1991. The District’s review of the current federal regulations indicated that some of those 

provisions would weaken the District’s current (1991) regulatory program. As required by 

SB288, the District’s rule excludes or replaces those PSD Reform provisions. In light of the 

revisions, the District prepared this analysis to verify to EPA that the new Rule 203 is at least as 

stringent as the PSD Reform rules.

Background

A. Federal Program

On December 31, 2002, the U.S. Environmental Protection Agency (EPA) revised its regulations 

governing the New Source Review (NSR) programs, including PSD requirements, under parts C 

and D of Title 1 of the Clean Air Act. (67 Fed. Reg. 80185). The rulemaking included the 

following five features at issue here:

1. 10-year Look-back for Establishing Emissions Baseline: PSD requirements are 

triggered when emission increases for a new project or modification exceed specified 

levels. The emission increase is measured by comparing estimated new emissions to a 

baseline emission. The federal rule changes how the baseline emissions are calculated. 

The rule allows the facility to use any 24-month period in the previous 10 years as long 

as all current control requirements are taken into account. Rule 203 (1991) and 

proposed Rule 203 limited the look back to the prior 24 months, unless the District

agrees with the facility that the prior 24 months are not representative.

2. Calculating Emissions Increases: The rule added an optional method for calculating

increases in emissions resulting from facility modifications at non-electric utility steam 

generating units (non-EGU’s). The federal rule now requires a source to use an actualto-projected actual test (past actual emissions compared to the estimated actual

emissions after the change). The source has the option to use an actual to potential test 

(past actual emissions compared to the maximum potential emissions after emission 

controls, taking in to account all enforceable restrictions) to avoid some monitoring and 

 

1

40 CFR §52.21 et al. The 2002 rule changes affect nonattainment New Source Review (NSR) as well 

as PSD, but for brevity and clarity, some references to NSR are excluded from this discussion.

2

40 CFR §51.166 (a)(7)(iv)

3

EPA has not acted on the 1991 rule.
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January 28, 2011

Page 2

recordkeeping requirements associated with the projected actual method. Rule 203 

(1991) and proposed Rule 203 only allow an “actual-to-potential” test.

3. Plantwide Applicability Limits (PALs): The rules were modified to allow facilities to 

make changes to their operations without triggering PSD, so long as a facility agrees to 

operate within a strict facility wide emissions cap, called a Plantwide Applicability Limit or 

PAL. Rule 203 (1991) and proposed Rule 203 do not include PALS.

4. Pollution Control and Prevention Projects: The rules created a process allowing

facilities that undertake environmentally beneficial projects to avoid emission controls for

ancillary emissions increases resulting from the installation of certain pollution control 

and prevention projects. Rule 203 (1991) and proposed Rule 203 do not include a 

similar program.

5. Clean Unit Provision: The rules gave facilities that install “clean units” operational 

flexibility if they continue to operate within permitted limits. Clean units must have an 

NSR permit or other regulatory limit that requires the use of the best air pollution control 

technologies. Rule 203 (1991) and proposed Rule 203 do not include a similar 

provision.

The last two features were vacated by the U.S. Court of Appeals for the District of Columbia in 

State of New York, et al., v. U.S. Environmental Protection Agency, et al., 413 F.3d 3 (D.C. Cir 

2005), and are no longer part of the federally revised program. 

B. Sacramento SIP Call

In December 2010, EPA made a finding4(referred to as a SIP Call) that California’s State 

Implementation Plan (SIP) is substantially inadequate to meet CAA requirements because 

Sacramento’s approved PSD rule does not require emission controls for GHG-emitting sources. 

The SIP Call sets a deadline of January 31, 2011 for the District to submit a revised PSD rule. 

In addition to the changes needed to meet CAA requirements for PSD Reform for all regulated 

pollutants, including GHG, amendments to Rule 203 must conform to the requirements of the 

Protect California Air Act of 2003 (referred to as SB288). This California law prohibits districts

from adopting new or revised rules that weaken:

“those new source review rules and regulations for both nonattainment and prevention of 

significant deterioration for new, modified, repaired, or replaced sources that have been 

adopted by the district governing board on or prior to December 30, 2002, that have 

been submitted to the EPA by the state board for inclusion into the SIP and are pending 

approval or have been approved by the EPA5.”

The most recent PSD rule adopted by the District and submitted to EPA for inclusion in the SIP

is the 1991 version of Rule 203. Consequently, the 1991 rule provides the SB288 comparison 

baseline. To meet SB288, proposed Rule 203 excludes or modifies the 2010 federal PSD rule 

for certain Reform provisions. The specific provisions excluded or modified include: Major 

 

4

Action to Ensure Authority to Issue Permits under the Prevention of Significant Deterioration Program to 

Sources of Greenhouse Gas Emissions: Finding of Substantial Inadequacy and SIP Call, Final Rule”, 

Federal Register, Volume 75, page 77698. December 13, 2010 (75 FR 777698)

5 California Health and Safety Code § 42504(a), § 42505
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January 28, 2011

Page 3

Modification definition, Baseline Actual Emissions definition, Actual-to-Projected-Actual 

applicability, and Plantwide Applicability Limitations. 

Sacramento Equivalency Determination Analysis

PSD Reform permits states to deviate from the new federal regulations, but requires that states 

that do so show that their existing program is at least as stringent as the PSD Reform 

provisions6. This analysis fulfills that requirement. 

A. Stringency of state and local requirements in the Sacramento area subsumes

voluntary reductions anticipated in PSD Reform

PSD Reform’s environmental impact analysis relies on benefits from encouraging facilities to 

voluntarily implement emission controls. There are several factors that render this result 

unlikely, if not impossible, in Sacramento. The first category of factors relates to the stringency 

of the Non-PSD program, the second relates to requirements under state laws on climate 

change, and the third relates to the applicability to Sacramento of some of EPA’s key analytical 

assumptions.

The stringency of state and local rules stems from the District’s attainment status for various 

pollutants. We achieved the federal standard for carbon monoxide over a decade ago, when 

EPA re-designated Sacramento to attainment for carbon monoxide. But, although air quality in 

the region has been steadily improving, Sacramento has been nonattainment for federal ozone 

and particulate matter air quality standards for decades. And while the area recently submitted a 

re-designation request under the federal 1-hour ozone standard, we still do not meet the more 

stringent 8-hour ozone standard. The District has requested re-designation to attainment for 

PM10, and ARB has approved the request and forwarded it to EPA for final approval. 

Sacramento remains nonattainment for PM10 until EPA approves the request, but we still do not 

meet the PM2.5 standard. 

To achieve and maintain the federal standards, California and the District have established 

some of the most stringent rules in the nation to control carbon monoxide (CO), particulate 

matter and ozone precursors (NOx, and VOC) and sulfur oxides (as a precursor to particulate 

matter) to meet federal attainment or maintenance requirements. Because of the severity of air 

quality problems in the area, state and federal laws and regulations require SMAQMD to 

regularly review its rules and make changes to those rules to insure sources implement the best 

available controls on new and modified sources and best available retrofit control technologies7. 

Although nonattainment pollutants are not subject to PSD rules, because all of the potential 

PSD sources also emit nonattainment pollutants, regulations directed at nonattainment 

pollutants frequently provide significant ancillary reductions in attainment, GHG and other 

regulated pollutants. For example, with a few exceptions, Sacramento’s PSD sources exceed 

PSD applicability thresholds because of their combustion emissions, and combustion emissions 

include PSD pollutants (GHGs, CO, and NO2) as well as nonattainment pollutants, NOx, VOC 

(as precursors to ozone) and PM2.5 and its precursors. Therefore, state and local 

nonattainment pollutant rules directly affect the potential PSD sources and their emissions.

In addition to the stringent local requirements contained in the District’s attainment and 

nonattainment programs, recent state laws affecting GHG’s will further tighten the mandatory 

 

6

40CFR51.166(a)(7)(iv)

7 California Health and Safety Code Section 41010(b) and California Code of Regulations Title 17, 

Division 3, Chapter 1.5, Article 6, Section 70601
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controls on pollutants in the District. State law AB32, has and will continue to require controls 

on GHGs, including energy efficiency and emissions reductions8. AB32 (California State Climate 

Change Law) and California’s Cap and Trade rule9go beyond federal PSD requirements. AB32 

will help put California on the path to meet its goal of reducing GHG emissions to 1990 levels by 

the year 2020, ultimately achieving an 80% reduction from 1990 levels by 2050. Under cap-andtrade, an overall limit on GHG emissions from capped sectors will be established and facilities 

subject to the cap will be able to trade permits (allowances) to emit GHGs.

These historic and on-going requirements, which are unaffected by PSD Reform, already 

significantly limit the emissions from stationary sources in Sacramento County. The combined 

impact of state and local laws and rules, including AB32 and its Cap and Trade program, is to 

limit opportunities for additional voluntary controls and make any remaining opportunities for 

additional voluntary controls much more expensive than in other parts of the country.

Consequently, PSD Reform provisions that arguably create an incentive for sources to 

implement voluntary controls or reduce emissions will be ineffective in Sacramento County.

B. The EPA’s Supplemental Analysis is flawed and does not account for the 

invalidation of a portion of Reform

At the time Reform was approved, EPA made a determination that the Reform provisions are 

more stringent than the pre-2002 base program from a nationwide perspective. The 

determination did not include state- or district-specific evaluations. The decision relied primarily 

on the agency’s “Supplemental Analysis of the Environmental Impact of the Final NSR 

Improvement Rule (November 21, 2002) (hereinafter “Supplemental Analysis”), which examined 

the changes, using the federal regulations as the comparison baseline. This study relied largely 

on anecdotal evidence and concluded that final revisions were “environmentally beneficial” 

based on the assumption that all five of the revisions would be implemented together. (67 Fed. 

Reg. 80185, 80241, see also Supplemental Analysis p.2.) However, since two of the five 

measures, Clean Units and Pollution Control Project exemption, were vacated by the Court of 

Appeals, EPA’s conclusion that there is a net environmental benefit is out-dated. 

In addition, a Government Accounting Office study found that [the Supplemental Analysis] did 

not adequately represent the revised rule’s effect on: (i) energy efficiency projects industry wide, 

or (ii) the impact of Reform on overall emissions under the new federal rules. See EPA Should 

Use Available Data to Monitor the Effects of Its Revisions the New Source Review Program, 

GAO-03-947, August 2003. pp. 23-24. Appendix 2 . See also Reform or Rollback?: How EPA’s 

Changes to New Source Review Affect Air Pollution in 12 States, Environmental Integrity 

Project and the Council State Governments/Eastern Regional Conference, July 28, 2003. 

Appendix 3.

C. The EPA’s Supplemental Analysis of the impacts of PSD Reform does not reflect 

conditions in Sacramento

EPA’s Supplemental Analysis relied heavily on reductions from the application of PALs to six

sources10 and extrapolated those results to assess impacts in three industrial categories:

 

8 California Health and Safety Code commencing with Section 38500

9

Additional information on the Cap and Trade program can be found at 

http://www.arb.ca.gov/cc/capandtrade/capandtrade.htm

10 U.S. Environmental Protection Agency, New Source Review (NSR) Improvements: Supplemental 

Analysis of the Environmental Impact of the 2002 Final NSR Improvement Rules, November 21, 2002. 
SMAQMD Equivalency Determination for Rule 203

January 28, 2011

Page 5

pharmaceutical manufacturing, semi-conductor manufacturing, and automobile manufacturing. 

None of these types of PSD facilities are located within Sacramento County, and, therefore, the 

emission benefit estimate would not apply here. To address this, the District’s analysis followed 

EPA’s general protocol by analyzing existing sources for key regulated PSD pollutants common 

to nearly all of the potentially impacted PSD sources in Sacramento County. This analysis

considered the impact if the PSD determinations were made today, using each source’s 

emissions information. We also used each sources’ permitting history to provide supplementary 

information for the analysis of impacts of potential future permitting actions. As demonstrated 

below, the analysis established that PALs implementation would provide fewer emissions 

reductions than implementation of proposed Rule 203. 

In addition to the PALs analysis, the District reviewed the relative stringency of the applicability 

tests and emissions baseline revisions when compared to the proposed rule, and found that 

those Reform provisions provide no benefits in Sacramento. The EPA analysis already 

conceded that: (i) the actual-to-projected actual test is likely to have only a limited environmental 

benefit, and (ii) the change in the emissions baseline may allow a small number of sources to 

avoid PSD permitting because of the availability of a higher baseline11. Our analysis confirmed 

that the proposed rule would result in more emission reductions than either of the Reform 

revisions. 

1. Identification of Potential PSD Facilities in Sacramento

This analysis followed EPA’s general protocol by analyzing existing sources for key regulated 

PSD pollutants common to nearly all of the potentially impacted PSD sources in Sacramento 

County; GHGs12, NO2

13, CO, and PM10 (to ensure that a potential future EPA re-designation to 

attainment for PM10 would not yield different conclusions). Table 1 identifies the potential to 

emit for the ten facilities that could be affected by PSD. We did not evaluate VOC because it is 

an ozone precursor subject to nonattainment NSR rather than PSD. We also did not analyze

SO2 because no facility exceeds the 250 TPY PSD threshold. In fact all of the facilities but one 

were less than 15 TPY for this pollutant. 

As indicated in Table 1, ten facilities in Sacramento County have a current potential to emit

(PTE) NOx, PM10, or CO greater than 250 TPY or CO2e in excess of the 100,000 TPY 

threshold and consequently may trigger PSD requirements if they make a major modification to 

their facility.

 

Page 2 and Appendix A- “Evaluation of Implementation Experiences with Innovative Air Permits”, EPA 

Office of Air Quality Planning and Standards (not dated)

11 U.S. Environmental Protection Agency, New Source Review (NSR) Improvements: Supplemental 

Analysis of the Environmental Impact of the 2002 Final NSR Improvement Rules, November 21, 2002. 

Page 2.

12 This analysis uses GHGs expressed as CO2e as defined in 40CFR51.166(b)(48)(i–ii). 

13 The analysis uses NOx emissions because NO2 data is not readily available.
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January 28, 2011

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Table 1

Facility Type PTE Emissions TPY Estimated 

PTE 

TPY CO2e

VOC NOx SOx PM10 CO GHG

SMUD, Cosumnes Power Plant 29.99 125.6 10.96 80.2 297.75 1,953,320

SMUD, SCA Power Plant 16.81 58.77 3.86 34.92 99.34 808,625

SMUD, SPA Power Plant 19.96 49.9 3.72 22.54 43.69 711,519

SMUD, Carson Ice Power Plant 18.29 53.35 11.51 19.0 100 404,354

Campbell Soup Soup manuf 3.14 61.98 0.62 7.77 54.36 238,674

UCD Medical 

Center

Power Plant/Space 

Heating

26.5 21.16 0.7 12.24 40.85 201,820

County of 

Sacramento - Kiefer

Landfill 62.5314 87.5 90.66 27.07 445.74 182,136

SMUD, McClellan Power Plant 4.5 24.65 3.83 10.44 73.32 154,100

State of California

GS

Space Heating 10 15 99 140,020

Aerojet Defense Contractor –

Rocket Motors

124 84 2 289 453 62,141

2. Plantwide Applicability Limits15

Proposed Rule 203 excludes all federal PSD requirement provisions related to Plantwide 

Applicability Limits (PALs) in 52.21(aa). That section allows a source to request a PSD PAL; 

once a PSD PAL is established, changes

16 can be made at the facility so long as the facility’s 

actual emissions remain below the PAL. The PAL level is the source’s baseline actual 

emissions plus the PSD significance levels17. The PAL must be adjusted downward to reflect 

the benefits of any known new requirements that will affect the facility. Increases in PAL levels 

to account for new or modified equipment are only allowed in limited circumstances18. PALs 

limits expire after 10 years, and the source has the option to allow the PAL to expire (and cease 

being an operational restriction) or to revise the PAL.

EPA’s Analysis states19, that “a PAL, is an optional approach that will provide you, the owners or 

operators of major stationary sources, with the ability to manage facility-wide emissions without 

triggering [PSD]” (emphasis added). EPA further states20 that PALs promote “voluntary 

improvements in pollution controls by creating an incentive for you [sources] to control existing 

and new emissions units”. EPA goes on to describe the benefits achieved under PALs using 

the results from a study21 of VOC emissions under six permits that included PAL-like provisions. 

EPA extrapolated that study’s results to estimate the potential VOC emissions reductions from 

PALs for three source categories: pharmaceuticals, semiconductors, and automobile 

manufacturing (auto manufacturing does not include auto parts manufacturing or automobile 

refinishing)22. EPA’s analysis included estimated VOC emissions benefits from PALs based on 

assumptions about the percentage of sources that might opt to participate in the PAL program 

 

14 This PTE limit excludes fugitive emissions from the landfill.

15 This section pertains to 40 CFR 51.166(a)(7)(iv)(a)

16 The types of change allowed are specified in 52.21(aa)(1)(i)

17 Significance levels are specified in 52.21(b)(23)

18 Restrictions are in 52.21(aa)(11)

19 Quote taken from 67FR80206 IV.A. paragraph 1, December 31, 2002

20 Quote taken from 67FR80206 IV.A. paragraph 2, December 31, 2002

21 “Evaluation of Implementation Experiences with Innovative Air Permits”, EPA Office of Air Quality 

Planning and Standards (not dated)

22 EPA’s Supplemental Analysis, Section III.A.
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January 28, 2011

Page 7

and the percentage of additional emissions reductions that might be achieved by establishing a 

PAL below the facility’s current potential to emit. 

EPA’s analysis and conclusions do not support adoption of PSD Reform in Sacramento 

because: (i) sources are implementing facility improvements in response to other programs, and 

PALs will not affect the rate of these improvements through implementation of additional 

voluntary controls, (ii) the use of VOC’s as a measure of reductions is inappropriate in 

Sacramento because here VOC emissions are subject to NSR requirements, not PSD 

requirements, (iii) existing facility-wide limits are more stringent under Proposed Rule 203 than 

the Reform PAL limits, and (iv) the PSD Reform monitoring and recordkeeping requirements are 

met through the Rule 203 and Title V requirements, and therefore PSD Reform does not provide 

any added protections. 

a. Voluntary Controls

As discussed in more detail in section C.4., the severity of air quality problems in Sacramento 

and state laws and regulations require SMAQMD to regularly review our rules and make 

changes to those rules to require sources to implement the best available controls on new and 

modified sources and best available retrofit control technologies on existing sources23. 

Additionally, state law AB32 (California State Climate Change Law), has and will continue to 

impose controls on GHGs, including energy efficiency and emissions reductions. AB32 and 

California’s Cap and Trade rule24 goes beyond federal PSD and other potential new control 

requirements. AB32 will help put California on the path to meeting its goal of reducing GHG 

emissions to 1990 levels by the year 2020, and ultimately achieving an 80% reduction from 

1990 levels by 2050. Under cap-and-trade, an overall limit on GHG emissions from capped 

sectors will be established by the cap-and-trade program and facilities subject to the cap will be 

able to trade permits (allowances) to emit GHGs.

These programs are a critical tool in bringing down emissions from Sacramento’s PSD sources. 

Nearly all of Sacramento’s potential PSD sources are directly regulated by the Cap and Trade 

program, including five of Sacramento’s largest emitters, the electrical generating facilities 

operated by or contracted to SMUD. Individual sources decide how to meet the emission caps 

established by the cap-and trade rules. Compliance will likely require installation of controls and 

other efficiency improvements. The combined impact of state and local laws and rules, including 

AB32 and its Cap and Trade program, is to limit opportunities for controls that go beyond 

requirements, making any remaining opportunities for additional voluntary controls much more 

expensive than in other areas of the country. Consequently, Reform provisions that arguably 

create an incentive for sources in other states to implement voluntary controls or reduce 

emissions will be ineffective for PSD sources in Sacramento County.

b. VOC emissions and NSR

Sacramento violates the federal ozone standard and consequently ozone precursor emissions, 

like the VOC emissions analyzed by EPA, are subject to NSR requirements, not PSD 

requirements. As a result, implementation of PSD Reform will have no impact on the emission 

of VOCs within Sacramento, and Sacramento will likewise not see any of the VOC emission 

benefits identified in EPA’s Supplemental Analysis. 

 

23 California Health and Safety Code Section 41010(b) and California Code of Regulations Title 17, 

Division 3, Chapter 1.5, Article 6, Section 70601

24 Additional information on the Cap and Trade program can be found at 

http://www.arb.ca.gov/cc/capandtrade/capandtrade.htm
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January 28, 2011

Page 8

c. Potential PALs

Instead of evaluating VOC emissions, the District evaluated the potential PAL emission benefits 

based on attainment pollutant emissions from PSD sources. The resulting equivalency 

determination found that if Rule 203 included PAL provisions, almost all PALs would be higher 

than facility-wide emissions caps already established for Sacramento’s existing PSD sources, 

and therefore, the new PALs provide no emission benefits. In the few instances in which this 

initial look indicated PALs might provide emissions benefits, we examined the permitting history 

to assess the likelihood that the source will opt to establish a PAL, and concluded that that 

result is unlikely.

Rule 203 PSD applicability determinations consider any facility-wide permit limitations that are

federally enforceable. All of Sacramento’s existing facilities potentially subject to PSD already 

have facility-wide emission limitations for the PSD pollutants analyzed, CO, NOx and PM10. 

The emissions benefits from PAL provisions only occur if the facility’s PAL is lower than their 

current permitted emissions level. This equivalency determination evaluated whether any of 

Sacramento’s potential PSD facilities could establish a PAL that is lower than their current 

facility-wide emissions limit. If not, the PALs provide no emissions benefits. 

As shown in Attachment B, nearly all of the potential PSD sources have existing facility-wide 

emissions limitations that are more stringent than the potential PAL limits. Consequently, the 

PALs provide no emission benefits in those instances. 

Where the PAL was more stringent than the facility-wide emissions limit, we then evaluated the 

difference between the PAL and the permitted emissions limit and the source’s permitting 

history to estimate the likelihood of the source exercising its option to request a PAL. The 

federal rules do not require a source to accept a PAL, therefore, any potential emission benefits 

from PALs will only occur if the source chooses to accept a PAL in exchange for increased 

flexibility under PSD Reform. 

In the specific cases where the PAL would be lower than facility-wide emission limitations, the 

PAL is roughly half or less of current emissions limits. This occurs in all cases except two 

sources. It is unlikely that a source would request a PAL that so substantially limits future 

increases in their actual emissions. For those two exceptional sources, discussed below, only 

the NOx PAL is close to the source’s emissions limit. 

The first case is Campbell Soup. The facility’s permitting history shows several changes and 

additions, including emissions control retrofits that required local NSR permits. This history does 

not suggest that any perceived inflexibility under the current rules is limiting changes at their 

facility. The second exceptional source, Cosumnes Power Plant, was permitted in 2004. 

Cosumnes was required to install LAER NOx controls (2 ppm NOx emissions limit) and already 

employs state-of-the-art fuel efficiency technology. Since Cosumnes already employs controls 

that go beyond PSD NOx BACT requirements, it also would most likely meet PSD BACT

requirements if modifications were made. Furthermore, SMUD prepared tentative expansion 

plans for Cosumnes, and those plans show that the expansion would likely trigger PSD 

regardless of whether the PAL limit were established. PAL restrictions would therefore only limit 

utilization levels, and consequently, there would be no incentive for the facility to propose or 

accept a PAL. 
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January 28, 2011

Page 9

d. Monitoring and Recordkeeping

All but two of the potential PSD facilities currently have Title V permits that contain adequate 

monitoring and recordkeeping provisions to ensure compliance with the required emissions 

limitations. Those two facilities that do not currently have Title V permits will be required to get 

a Title V permit if their GHG potential to emit exceeds the Tailoring Rule’s Title V applicability 

thresholds. Therefore, the monitoring and reporting provisions associated with PALs provide no 

emissions benefits.

e. Conclusion

Based on the circumstances and sources specific to Sacramento, the District concludes that 

Rule 203 is at least as stringent as the PAL provisions in EPA’s PSD Reform program.

3. Baseline Actual Emissions (10 Year Look-back Revision)

25

Proposed Rule 203 modifies the definition of “baseline actual emissions” for all regulated PSD

pollutants except GHGs, by requiring use of the average rate, in tons per year, at which the unit 

actually emitted the pollutant during the 24-month period preceding the application date. The Air 

Pollution Control Officer may allow the use of a different time period if the source demonstrates

that it is more representative of normal source operation.26 The alternative period must use two 

consecutive years during the prior 5-year period. PSD Reform allows the baseline look-back 

period to consider any 2 consecutive years out of the last 10 years. The lower the baseline 

number, the more likely the facility will trigger PSD requirements.

In the Supplemental Analysis, EPA states27 that “the overall consequences of the baseline 

change will be negligible.” EPA acknowledged28 that “it is very difficult to model source behavior 

sufficiently to predict whether emissions benefits will be lost or gained” and notes29 that the 

Reform change will not affect the baseline for most sources, including new sources, 

modifications in the largest-emitting category (coal fired power plants), modifications at sources

where emissions have been highest in recent years, and modifications at sources where 

emissions have been relatively stable. EPA also noted that the new baseline would not apply if 

the present emissions are lower due to enforceable controls or limitations, which EPA indicated

is true 70% of the time. According to EPA, then, the only sources that will receive a higher 

baseline under PSD Reform will be those whose low emission years are due to decreased 

utilization due to decreased market demand, outages, or other circumstances. EPA noted30 in 

their analysis that they would be unable to estimate what emissions consequences -- if any --

would result for these types of sources, but stated that the number of sources receiving different 

baselines likely represents a very small fraction of the overall NSR permit universe, and 

because the baseline may shift either direction, EPA concluded that any overall consequence 

would be negligible.

 

25 This section pertains to 40 CFR 51.166(a)(7)(iv)(b)

26 District’s permitting policies limit the “representative” period to the last five years. 

27 EPA’s Supplemental Analysis, p. 2

28 EPA’s Supplemental Analysis, p. 13

29 EPA’s Supplemental Analysis, p. 13

30 EPA’s Supplemental Analysis, p. 13
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January 28, 2011

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To analyze the potential PSD Reform impacts on baseline assumptions in Sacramento, 

SMAQMD used31 the actual emissions from the last 10-11 years for the 10 facilities listed 

above. Cosumnes Power Plant has only been in operation for 5 years, so we used those years. 

The results are presented in Attachment A.

The analysis looked at the historical emissions of NOx, PM10 and CO. For eight of the facilities,

the baseline actual emissions using the District’s rule is lower for emissions of NOx and PM10

than the baseline actual emissions would be using the PSD Reform approach. For two facilities,

the baseline actual emissions are the same regardless of which rule is used.

For CO emissions, 4 facilities have lower baseline actual emissions under the District rule than 

the baseline actual emissions using PSD Reform. For 3 facilities, the baseline actual emissions 

for the last 2 years (District rule) is lowest, the baseline actual emissions using 2 out of 5

(District rule) or 2 out of 10 (PSD Reform) would be the same. For the other 2 facilities, the 

baseline actual emissions are the same regardless of which rule is used. Since there would be 

no difference in the baseline if you allowed 2 out of 10 years, SMAQMD’s proposed Rule 203 

CO baseline would be equivalent for those five facilities. For NOx and PM10 and the remaining 

CO sources, SMAQMD’s proposed Rule 203 would be more stringent than NSR Reform.

For the type and size of facilities operating within Sacramento County, including the 10 year 

look-back period would establish higher baseline emissions for most of the existing facilities. 

Using a higher baseline would allow sources to potentially avoid the applicability of PSD 

requirements, and therefore, potentially avoid the imposition of controls. For those cases where 

it wouldn’t establish a higher baseline than proposed Rule 203, the baseline actual emissions 

would be equivalent to the current federal PSD rules.

Based on the above data, the District believes that the Rule 203 look-back for the 24-month

period preceding the date of application, and allowing a different time period to be used (within a 

five year window) if that period is more representative of normal source operation, is at least as

stringent as the federal requirements.

4. Actual-to-Projected-Actual Test (Applicability determination)32

Proposed Rule 203 uses an actual-to-potential applicability test. PSD Reform gives sources the 

option of using an actual-to-projected-actual applicability determination (with the subsequent 

recordkeeping requirements) as an alternative to using the actual-to-potential applicability 

determination. EPA’s intent is to encourage facility improvements by decreasing the likelihood 

that the change will trigger air permit requirements. This rests on the assumption that facilities 

in the pre-Reform realm avoided improvements because of the permit requirements. This 

assumption does not hold true in Sacramento, where other forces provide adequate incentive to 

implement facility improvements, even in the face of added air permit requirements. As a 

consequence, for Sacramento, the result of Reform would be to reduce the number of these 

projects that are subject to air quality controls, and thereby increase air emissions. 

EPA’s Supplemental Analysis stated that33 the actual-to-potential methodology “discourages 

[sources from making] certain environmentally beneficial changes and actually provides an 

incentive to keep actual emissions high” and claimed that therefore there is an “adverse 

 

31 California Air Resources Board, Secure District Resources, last accessed January 19, 2011, 

<http://www.arb.ca.gov/ei/drei/eitac/secure/secure.htm>

32 This section pertains to 40 CFR 51.166(a)(7)(iv)(c) and 40 CFR 51.166(a)(7)(iv)(f)

33 EPA’s Supplemental Analysis, Appendix G, p. G-1
SMAQMD Equivalency Determination for Rule 203

January 28, 2011

Page 11

environmental impact from sources that trigger NSR under the actual to potential test, but not 

the actual to projected actual test. In short, they argue that the actual-to-potential test drives 

facilities to avoid or delay changes that would have resulted in emission reductions for fear of 

the cost associated with added controls or permit timeframes imposed by the actual-to-potential 

test. 

However, the historical information for Sacramento demonstrates that our industries have 

implemented sophisticated state-of-the-art facility improvements despite application of the 

actual-to-potential test and the resulting permit and emission control requirements. It is unlikely 

that additional upgrades exist that have been deliberately shunned by industries trying to avoid 

the applicability of PSD requirements. As discussed previously, state laws and local rules either 

require or create voluntary incentives for sources to implement energy efficiency strategies and 

other control strategies that reduce or limit actual emissions. For example, all of the electric 

utility facilities in Sacramento County are natural gas combined or simple cycle gas turbines 

using state of the art controls that emit less than 5 ppm of NOx. These sources represent five of 

the 10 PSD sources. SMUD or its contracted power producers have recently implemented 

energy efficiency improvements on 2 of their five facilities. And, while EPA argues that facilities 

have avoided improvements to keep actual emissions high and preserve their related permit 

limits, that has not been the case in Sacramento. For example, the actual emissions at Aerojet, 

another PSD source, are a small fraction of their permitted emissions levels (10% or less). 

Clearly, existing rules are not causing that source to keep actual emissions high. The actual 

emissions and recent control strategy changes made at each source are discussed in Appendix 

A. All of the potential PSD sources analyzed have continued to make modifications at their 

facility for energy efficiency, plant expansion, or product demands.

EPA acknowledges34 that there are cases where emissions increases could trigger NSR under 

the actual-to-potential test but not under the actual-to-projected actual test. In fact, that is the 

crux of their argument – that sources avoid improvements to evade the related controls imposed 

under the actual-to-potential test and resulting permit requirements. But since sources in 

Sacramento are continuing to make facility upgrades under the existing actual-to-potential test, 

this area would not experience the uptick in facility improvements anticipated by EPA and would 

simultaneously be giving up the emission reductions that come with requiring the emission 

controls imposed through the permit review process. 

EPA’s Supplemental Analysis also identified two scenarios35 in which the Reform actual-toprojected actual approach would be less stringent than the District’s actual-to-potential 

approach. First when an actual-to-potential test shows an increase but the source avoids PSD 

requirements by taking a permit limit. EPA dismisses this scenario stating36 that PSD Reform 

rules would “effectively limit their emissions in the same fashion,” meaning the projected actual 

estimate will limit the facilities emissions to the same level as the permit limit under the District 

program. The flaw in this analysis is that the projected actual estimate is difficult to identify and

enforce, while a permit limit violation is clear. The second scenario concerns sources that will 

have an actual emission increase, but cannot take the permit limit and instead are reviewed 

under PSD (implementing additional controls). EPA dismisses this scenario by stating37 that 

“this is [an] extremely rare case and [EPA is] unaware of any example”. But by requiring the 

actual-to-potential test, Rule 203 would achieve additional reductions, however rarely the 

 

34 EPA’s Supplemental Analysis, p. 14

35 EPA’s Supplemental Analysis, Appendix G, p. G-4&5

36 EPA’s Supplemental Analysis, Appendix G, p. G-5

37 Ibid.
SMAQMD Equivalency Determination for Rule 203

January 28, 2011

Page 12

instance arises. Furthermore, if facilities are in fact rarely reviewed under PSD (instead taking 

permit limits), than the need for PSD Reform is mooted.

Evidence in this analysis shows that there are no benefits from removing perceived 

disincentives to making environmentally beneficial changes and that maintaining the actual-topotential test has and will continue to provide emissions benefits achieved by implementing 

BACT emission control requirements at the point of construction, when adding controls is at its 

most cost effective. Therefore, SMAQMD concludes that the actual-to-potential test is at least 

as stringent as the current federal PSD rule.

5. Major Modification38

Proposed Rule 203 defines a major modification as any physical or operational change at a 

major stationary source that would result in a cumulative significant net emissions increase. 

PSD Reform would only classify a major modification as significant if it would result in a 

significant increase both individually and cumulatively. In other words, unlike the proposed rule, 

PSD Reform would not consider accumulated emissions from a series of less than significant 

emissions increases if the emissions increase from the proposed modification to the source is, 

standing alone, less than significant.

The historical information for Sacramento demonstrates that for our industries, the typical permit 

modifications are for individual projects that individually emit less than the PSD significance 

levels. Under proposed Rule 203, a major modification would be triggered if the 5 year 

accumulation of less than significant emissions changes is significant. Under PSD Reform, a 

major modification would only be triggered if both tests are met – the proposed modification is 

greater than significant and the 5 year accumulation of emissions changes is significant. For 

example, if a source has made 5 individual “less than significant” modifications over the last five 

years, it would be a major modification under Rule 203, but not under PSD Reform.

SMAQMD concludes that excluding the first part of EPA’s major modification tests – is the 

proposed modification significant – and only including the significant net emissions increase part 

of the test is at least as stringent as the current federal PSD rule.

 

38 This section pertains to 40 CFR 51.166(a)(7)(iv)(a) and 40 CFR 51.166(a)(7)(iv)(b)

0

10

20

30

1 2 3 4 5

Emission Change NOx - TPY Proposed Rule 203

20 + 5 + 10 + 5 + 15 = 55 TPY > 40 TPY - major modification

PSD Reform

Proposed Modification 20 TPY < 40 TPY – not major modification

Second test doesn’t apply
SMAQMD Equivalency Determination for Rule 203

January 28, 2011

Page 13

6. Fugitive Emissions39

Proposed Rule 203 would include fugitive emissions in the same manner as the current federal 

regulations. The proposed Rule 203 adopts by reference 40 CFR 52.21 (in effect January 27, 

2011) including the definition of fugitive emissions. See also, the fugitive emissions discussion 

in Rule 203, Section 102.4 - Applicability and Rule 203, Section 205.3.h - Major Modification. 

No equivalency determination is needed for this provision.

7. New Emission Units40

Rule 203 requires the use of the actual-to-potential test for new emissions units in the same 

manner as current federal regulations. The proposed Rule 203 adopts by reference 40 CFR 

52.21 (in effect January 27, 2011). See also the new units discussion in Rule 203 , Sections 

201.4, 204.3, 206.8. No equivalency determination is needed for this section.

Conclusion

In Sacramento, because of the particular sources subject to the PSD rule, and because of the 

very stringent rules and regulations already in place, the proposed Rule 203 is at least as 

stringent as the federal PSD Reform rules. In fact, when the EPA’s analysis of the Reform 

provisions is applied to Sacramento – as opposed to the national review undertaken by EPA –

the proposed Rule 203 is more stringent than the Reform provisions. 

 

39 This section pertains to 40 CFR 51.166(a)(7)(iv)(b)

40This section pertains to 40 CFR 51.166(a)(7)(iv)(d) and 40 CFR 51.166(a)(7)(iv)(f)
SMAQMD Equivalency Determination for Rule 203

January 28, 2011

Page 14

ATTACHMENT A

10 YEARS OF OPERATING HISTORY
SMAQMD Equivalency Determination for Rule 203

January 28, 2011

Page 15

CO PM10 NOX VOC SOX GHG

Facility PTE (TPY) 297.75 80.20 125.60 29.99 10.96 1,953,320

Cooling Tower

Nox VOC PM10 CO Nox VOC PM10 CO PM10

2009 31.27335 1.7346435 19.4280072 16.351 31.2357 2.961445 13.08959 13.3026 0.75

2008 35.39665 1.9684515 15.747612 19.33565 31.25505 1.156223 12.08253 13.2072 1.29022

2007 33.39445 0.609045 11.8763775 9.86035 34.64185 1.26325 14.84319 16.2903 1.65435

2006 31.13 0.87 10.21 21.1 36.51 0.5 9.84 21.7 1.51

2005 4.2559 0.003702 0.0434985 16.3878 4.868 0.002589 0.050486 13.3901 0.033415

2004

2003

2002

2001 2004

2000

1999

1998

tons/year 2 yr ave tons/year 2 yr ave tons/year 2 yr ave

2009 62.51 64.58 33.27 31.19 29.65 31.10 Last 2 yr 2 out of 5 2 out of 10

2008 66.65 67.34 29.12 28.75 32.54 29.35 NOX 64.58 67.84 67.84

2007 68.04 67.84 28.37 24.97 26.15 34.48 PM10 31.19 31.19 31.19

2006 67.64 38.38 21.56 10.84 42.80 36.29 CO 31.1 36.29 36.29

2005 9.12 0.13 29.78

Cosumnes Power

Turbine A Turbine B

Nox PM10 CO

Recent Permitting

Plant constructed. PSD evaluation was 

included in the permitting of the plant.
SMAQMD Equivalency Determination for Rule 203

January 28, 2011

Page 16

CO PM10 NOX VOC SOX GHG

Facility PTE(TPY) 99.34 34.92 58.77 16.81 3.86 808,625

A B C Boiler A B C Boiler A B C Cooling Tower Boiler

2009 11.68 11.78 2.61 0.40 8.38 6.81 0.19 0.27 8.22 7.30 0.70 0.82 0.34

2008 15.29 25.39 3.67 0.27 9.90 7.80 0.23 0.14 7.67 9.30 1.08 0.52 0.18

2007 23.63 22.57 3.86 0.27 7.74 7.54 0.31 0.24 8.58 8.33 1.13 1.26 0.22

2006 24.46 24.19 2.66 0.20 5.39 6.79 0.24 0.21 8.95 8.78 0.85 1.25 0.15

2005 26.60 25.66 1.74 0.16 5.52 5.60 0.32 0.11 9.72 9.45 0.75 1.24 0.13

2004 26.32 27.55 2.48 0.53 7.93 5.08 0.37 0.25 9.52 10.07 0.94 1.25 0.52

2003 23.91 25.01 2.22 0.85 6.25 4.11 0.51 0.47 8.75 9.21 0.83 1.23 0.62

2002 27.68 25.08 5.57 0.80 7.04 5.51 0.72 0.59 10.13 9.15 2.02 1.24 0.54

2001 29.07 28.99 10.25 0.56 4.94 7.95 2.83 0.31 11.52 11.50 3.87 1.24 0.45

2000 28.48 26.71 0.00 1.10 1.95 5.37 0.00 0.19 12.75 11.67 0.00 1.24 0.62

1999 0.00 0.36 0.00 0.82 0.00 1.27 0.31

1998 0.00 0.32 0.00 0.02 0.00 1.27 0.12

2008/2009

tons/year 2 yr ave tons/year 2 yr ave tons/year 2 yr ave

2009 26.46 35.54 17.38 18.07 15.65 16.86

2008 44.62 47.48 18.75 19.14 18.07 16.95

2007 50.34 50.92 19.52 19.75 15.83 14.23

2006 51.51 52.83 19.98 20.64 12.63 12.09

2005 54.15 55.52 21.29 21.80 11.55 12.59

2004 56.88 54.43 22.30 21.47 13.63 12.49

2003 51.99 55.56 20.64 21.86 11.34 12.60

2002 59.13 64.00 23.08 25.83 13.86 14.95

2001 68.87 62.58 28.58 27.43 16.03 11.77 Last 2 yr 2 out of 5 2 out of 10

2000 56.30 48.03 26.28 23.70 7.51 5.26 NOX 35.54 52.83 64.00

1999 39.77 39.55 21.11 16.78 3.01 1.75 PM10 18.07 20.64 27.43

1998 39.33 12.44 0.49 CO 16.86 16.95 16.95

Sacramento Cogen Authority

Upgraded all three turbines for energy efficiency 

and lower Nox

NOX PM10 CO

Recent Permitting

19.53

11.05

PM10 Emissions

39.41

39.01

2.19

0.47

Nox emissions tons/year CO emissions tons/year
SMAQMD Equivalency Determination for Rule 203

January 28, 2011

Page 17

CO PM10 NOX VOC SOX GHG

Facility PTE (TPY) 43.69 22.54 49.90 19.96 3.72 711,519

Gas Turbine Duct Burner Gas Turbine NOX PM10 CO

MWH gen 14072 14071 21738

2009 849,628 5,838.25 68.66 0 28.73 11.56 1.89 2009 Control system for plant

2008 1,242,485 8,362.86 115.55 N/A 40.63 18.21 0.4 was replaced

2007 1,262,159 8,542.60 98.1 N/A 40.82 18.21 0.46

2006 983,067 7,849.31 76.285 37.55 16.66 0.52

2005 1,022,409 7,859.00 99 37.44 16.66 0.42

2004 1,185,201 9,004.00 133 46.03 19.13 0.29

2003 1,166,538 9,013.00 130 44.43 18.61 0.85

2002 1,237,733 9,495.20 245.2 46.63 20.66 2.25

2001 1,184,090 8,958.70 407.88 43.65 20.38 3.56

2000 1,194,215 9,410.00 367 43.28 20.03 2.69

1999 8,792.00 0.786 39.41 5.81 1.82

1998 7,830.43 12.055 35.58 4.88 2.01

tons/year 2 yr ave tons/year 2 yr ave tons/year 2 yr ave

2009 28.73 34.68 11.56 14.89 1.89 1.15

2008 40.63 40.72 18.21 18.21 0.4 0.43

2007 40.82 39.18 18.21 17.44 0.46 0.49

2006 37.55 37.49 16.66 16.66 0.52 0.47 Last 2 yr 2 out of 5 2 out of 10

2005 37.44 41.74 16.66 17.90 0.42 0.36 NOX 34.68 40.72 45.53

2004 46.03 45.23 19.13 18.87 0.29 0.57 PM10 14.89 18.21 20.52

2003 44.43 45.53 18.61 19.64 0.85 1.55 CO 1.15 1.15 3.13

2002 46.63 45.14 20.66 20.52 2.25 2.91

2001 43.65 43.46 20.38 20.21 3.56 3.13

2000 43.28 41.34 20.03 12.92 2.69 2.26

1999 39.41 37.49 5.81 5.35 1.82 1.92

1998 35.58 4.88 2.01

Sacramento Power Authority

mmcf/year

Nox PM10

Emissions tons/year Turbine/Duct Burner/Cooling Tower

CO

Recent Permitting
SMAQMD Equivalency Determination for Rule 203

January 28, 2011

Page 18

CO PM10 NOX VOC SOX GHG

Facility PTE (TPY) 100.00 19.00 53.35 18.29 11.51 404,354

Cooling Tower

Nox VOC CO PM10 Nox VOC CO PM10 Nox VOC CO PM10 PM10

2009 1.1045 0.323 1.1045 0.291 23.6885 9.351 64.9335 7.5195 0.20181 0.007731 0.102375 0.0059438 0.39

2008 1.6237 0.5036 0.676 0.411 26.5914 10.6839 75.1954 8.5851 0.50933 0.019512 0.258375 0.0150011 0.533845

2007 1.8645 0.591 0.6225 0.522 27.2725 10.997 69.4265 8.834 0.06727 0.002577 0.034125 0.0019813 0.54899

2006 1.62485 0.5046 0.56983 0.423325 22.80105 9.54835 71.8467 7.6831 0.25947 0.00994 0.131625 0.0076421 0.54054

2005 1.0775 0.3575 0.3255 0.2915 28.5455 11.1145 73.684 8.934 0.10571 0.00405 0.053625 0.0031134 0.54587

2004 1.4155 0.473 0.419 0.3855 28.803 11.523 67.2125 9.2675 0.055738 0.002135 0.028275 0.0016416 0.56472

2003 1.831 0.588 0.602 0.4795 27.4925 11.0635 67.8885 8.8985 0.0961 0 0.04875 0 0.547365

2002 4.42 1.44 1.13 1.17292 26.51 10.56 66.32 8.5 0.124475 0.005139 0.06305 0.0038064 0.52

2001 15.11 5.06 1.52 4.11 28.57 11.41 72.06 9.18 0.09 0 0.04 0 0.56

2000 13.22 4.29 0.56 3.48 28.34 11.2 60.2 8.87 0.1 0 0.05 0 0.55

1999 4.03 0.128874 0.08 1.1431 23.22 9.9 45.33 7.96 0.11 0.004393 0.06 0.002928 0.5456

1998 27.22 11.29 45.42 9.5 0.147 0.006062 0.0747 0.0044896 0.5456

2009/2010 Upgraded base turbine for energy

tons/year 2 yr ave tons/year 2 yr ave tons/year 2 yr ave efficiency and lower Nox

2009 24.99 26.86 8.21 8.88 66.14 71.14

2008 28.72 28.96 9.54 9.73 76.13 73.11

2007 29.20 26.94 9.91 9.28 70.08 71.32

2006 24.69 27.21 8.65 9.21 72.55 73.31

2005 29.73 30.00 9.77 10.00 74.06 70.86

2004 30.27 29.85 10.22 10.07 67.66 68.10

2003 29.42 30.24 9.93 10.06 68.54 68.03

2002 31.05 37.41 10.20 12.02 67.51 70.57 Last 2 yr 2 out of 5 2 out of 10

2001 43.77 42.72 13.85 13.38 73.62 67.22 NOX 26.86 28.96 42.72

2000 41.66 34.51 12.90 11.28 60.81 53.14 PM10 8.88 9.73 13.38

1999 27.36 27.36 9.65 9.85 45.47 45.48 CO 71.14 73.31 73.31

1998 27.37 10.05 45.49

Carson Ice

See Base Turbine

Peaking Turbine Base Turbine IC Engine Standby

NOX PM10 CO

Recent Permitting
SMAQMD Equivalency Determination for Rule 203

January 28, 2011

Page 19

CO PM10 NOX VOC SOX GHG

Facility PTE (TPY) 54.36 7.77 61.98 3.14 0.62 238,674

Adhesive Can Stamping Cold Cleaning Lab Solvent Eq Cleanup Can Coatings

TPY TPY TPY TPY TPY TPY

Nox VOC CO PM10 VOC VOC VOC VOC PM10 VOC VOC VOC Nox VOC CO PM10 Nox VOC CO PM10

2009 0.471 0.33 5.602 0.628756 0.07776 1.313999676 1.22 0.216859 1.76 0.47

2008 0.1824 0.2 1.539 0.28 0.11664 1.306958 0.58 0 1.764

2007

2006

2005 1.594 0.169 0.187 0.7997 0.1003 1.0621 0.6421 0 1.1

2004

2003 1.357 0.2675 0.586 0.37 0.0945 1.2895 0.68 1.7

2002 1.052 0.168971 0.149 0.42 0.1181739 0.8229276 1.048330001 0.07 1.5733029

2001 1.461 0.15 1.605 0.73 0.11 0.83 0.43 2.36

2000 1.23 0.140012 1.5 0.69 0.1 1.59 1.17 2.62 1.48

1999 0.89 0.106216 1.53 0.51 0.06 1.99 0.66 2.99 2.25

1998 3.32 0.381412 4.09 1.87 0.08 2.54 1.18 2.11 1.93 1.84 24.81 1.299 0.0305 0.309 0.138 1.35 0.0047 0.057 0.02

2008 Boilert retrofit for compliance w/411

tons/year 2 yr ave tons/year 2 yr ave tons/year 2 yr ave Occasional minor permit additions

2009 0.47 0.33 2.39 2.22 5.60 3.57

2008 0.18 2.04 1.54

2007

2006

2005 1.59 1.90 0.19

2004

2003 1.36 1.20 2.07 2.03 0.59 1.04

2002 1.05 1.26 1.99 2.54 1.50 1.55

2001 1.46 1.35 3.09 3.20 1.61 1.55 Last 2 yr 2 out of 5 2 out of 10

2000 1.23 1.06 3.31 3.41 1.50 1.52 NOX 0.33 0.33 1.35

1999 0.89 3.43 3.50 3.82 1.53 2.99 PM10 2.22 2.22 3.41

1998 5.97 4.14 4.46 CO 3.57 3.57 3.57

NOX PM10 CO

Recent Permitting

Campbell Soup

Boiler -NG Miscell Oven Heaters Thermal Oxidizer

TPY TPY TPY TPY
SMAQMD Equivalency Determination for Rule 203

January 28, 2011

Page 20

CO PM10 NOX VOC SOX GHG

Facility PTE (TPY) 40.85 12.24 21.16 26.50 0.70 201,820

Cooling Tower GDF

Nox VOC PM10 CO Nox VOC PM10 CO PM10 VOC Nox VOC PM10 CO

2009 0.427166 0.1811543 0.298821 0.066 7.900365 11.74287 4.89455 19.1027 1.2113938 0.0451302 3.20968973 0.091554 0.073817 0.361

2008 0.239261 0.1323178 0.293953 0.024 7.8594 11.54162 4.810675 27.43166 1.1440036 0.0454051 2.90536505 0.079079 0.064871 0.299

2007 0.570555 0.0844469 0.140299 0.072773 8.12409 11.94331 4.978105 25.38062 1.24016325 0.0476947 3.76698139 0.106263 0.086143 0.414828

2006 0.793348 0.1181244 0.194406 0.076773 7.425835 10.89911 4.542865 16.38008 1.1533503 0.0476947 3.37917326 0.095593 0.077817 0.370715

2005 1.387244 0.1789475 0.29611 0.554792 8.774335 12.722 5.30267 14.1336 1.17265705 0.0513447 2.89790835 0.082364 0.066613 0.328654

2004 0.738927 0.1099774 0.179973 0.022548 8.333035 12.15483 5.06627 16.888 1.2296058 0.052779 3.19165797 0.093333 0.074996 0.381355

2003 0.394543 0.06 0.098321 0.018989 8.731465 12.55342 5.232405 14.06949 1.2702 0.05 4.638971 0.129142 0.10523 0.50588

2002 1 0.19 0.26 0.003 7.52 10.85 4.52 17.18 1.2702 0.0476395 3.384 0.089 0.075 0.33

2001 0.65 0.11 0.16 0.01 12.98 17.63 7.35 2.07 1.27 0.08 3.72 0.129 0.077 0.965

2000 0.67 0.05 0.29 0.016 12.48 16.95 7.06 1.99 1.27 0.07 2.19 0.081 0.05 0.557

1999 2.81 0.16892 0.81 2.33 19.68 24.65 10.27 37.99 3.72 0.131775 0.07808 0.96

1998 9.96 0.409631 1.88 5.07 5.01 0.1757 0.10736 1.29

2010 Added additional IC engines for emercency use

tons/year 2 yr ave tons/year 2 yr ave tons/year 2 yr ave 2007-09 Modified boiler permits fro compliance w/411

2009 11.54 11.27 6.48 6.40 19.53 23.64 2008 Added additional IC engines for emercency use

2008 11.00 11.73 6.31 6.38 27.75 26.81 2005 Backup fuel change

2007 12.46 12.03 6.44 6.21 25.87 21.35

2006 11.60 12.33 5.97 6.40 16.83 15.92

2005 13.06 12.66 6.84 6.69 15.02 16.15

2004 12.26 13.01 6.55 6.63 17.29 15.94

2003 13.76 12.83 6.71 6.42 14.59 16.05

2002 11.90 14.63 6.13 7.49 17.51 10.28 Last 2 yr 2 out of 5 2 out of 10

2001 17.35 16.35 8.86 8.76 3.05 2.80 NOX 11.27 12.33 20.78

2000 15.34 20.78 8.67 9.91 2.56 21.92 PM10 6.4 6.4 9.91

1999 26.21 20.59 11.16 6.57 41.28 23.82 CO 23.64 26.81 26.81

1998 14.97 1.99 6.36

UC Med Center

Boilers Turbine IC Engine Standby

Nox PM10 CO

Recent Permitting
SMAQMD Equivalency Determination for Rule 203

January 28, 2011

Page 21

CO PM10 NOX VOC SOX GHG

Facility PTE(TPY) 445.74 27.07 87.50 62.53 90.66 182,136

Fugitive Other

Nox VOC PM10 CO Nox VOC PM10 CO Nox VOC PM10 CO VOC PM10

2009 4.0026109 0.0411842 0.0673009 0.599394 59.468 20.3016 12.675 400.7155 5.716 0.4605 1.2065 0.908 101.3952 0.171113975

2008 6.2815912 0.0620884 0.1044279 0.937155 63.6625 16.41 13.92644 402.665 8.159 1.1075 1.8065 3.403 100.43754 0.14619578

2007 5.6558001 0.0626129 0.0971682 0.853067 58.399 16.042 11.3977 323.1895 10.3395 3.195 3.981 9.9825 104.93561 0.18087663

2006 5.252163 0.0468466 0.0849404 0.776571 44.15 10.62068 10.71937 264.864 11.7375 8.33571 5.21848 10.821 106.76386 0.08499691

2005 5.7326154 0.100404 0.0890256 0.972494 50.732 6.8075 9.385348 275.6005 15.4245 10.807327 5.455815 13.599 102.26579 0.123305767

2004 45.73471 6.950688 7.38321 242.5338 15.51765 9.7060221 4.948945 11.97076 99.799107

2003 41.90711 6.519795 7.62 190.2632 9.482638 5.931225 2.99 10.8373 76.989541

2002 39.03521 6.609993 9.137283 205.8824 9.468384 5.4547589 2.6736 44.85024 74.348943

2001 32.33 6.47 11.65 228.61 6.19 1.74 1.24 16.08 73.75

2000 49.53 16.86867 2.46 206.48 3.59 1.81 1.28 19.11 79.08706

1999 1.48 1.57 0 4.92 14.42 7.26 5.15 76.73 57.285514

1998 14.47 7.25 5.14 76.65 56.826838

tons/year 2 yr ave tons/year 2 yr ave tons/year 2 yr ave 2010 Modified permit condition for control system

2009 69.19 73.64 14.12 15.05 402.22 404.61 2009 Added street sweeper

2008 78.10 76.25 15.98 15.82 407.01 370.52 2008 Modified permit condition for control system

2007 74.39 67.77 15.66 15.88 334.03 305.24

2006 61.14 66.51 16.11 15.58 276.46 283.32

2005 71.89 66.57 15.05 13.69 290.17 272.34

2004 61.25 56.32 12.33 11.47 254.50 227.80

2003 51.39 49.95 10.61 11.21 201.10 225.92

2002 48.50 43.51 11.81 12.35 250.73 247.71

2001 38.52 45.82 12.89 8.32 244.69 235.14 Last 2 yr 2 out of 5 2 out of 10

2000 53.12 34.51 3.74 4.45 225.59 153.62 NOX 73.64 76.25 76.25

1999 15.90 15.19 5.15 5.15 81.65 79.15 PM10 15.05 15.88 15.88

1998 14.47 5.14 76.65 CO 404.61 404.61 404.61

County of Sacramento PW Kiefer

IC Engine - Diesel IC Engine - Landfill Gas Flare

Nox PM10 CO Recent Permitting
SMAQMD Equivalency Determination for Rule 203

January 28, 2011

Page 22

CO PM10 NOX VOC SOX GHG

Facility PTE (TPY) 73.32 10.44 24.65 4.50 3.83 154,100

Nox VOC PM10 CO Nox VOC PM10 CO

2009 0.25 0.05 0.16 0.21 0.34 0.01 0.01 0.0673515 2003 Upgraded APC Controls - lowered Nox 

2008 0.28 0.05 0.16 0.6685 0.29 0.01 0.01 0.0673515

2007

2006

2005 0.62495 0.09946 0.294325 0.6301 0.0469 0.003723315 0.00335 0.0102

2004

2003 0.29855 0.042595 0.094455 0.3293 0.045024 0.00 0.003216 0.009792

2002 2.68 0.03199 0.95424 2.1 0.09 0.008785 0.00976 0.02

2001 9.67 1.32 3.90 5.58 0.09 0.01 0.01 0.01

2000 20.64 0.30 0.91 4.31 0.19 0.02 0.01 0.04

1999 11.04 0.13 0.38 3.04 0.26 0.02 0.02 0.06

1998 12.92 0.32 2.26 2.19 0.25 0.02 0.02 0.05

tons/year 2 yr ave tons/year 2 yr ave tons/year 2 yr ave

2009 0.59 0.58 0.17 0.17 0.28 0.51 Last 2 yr 2 out of 5 2 out of 10

2008 0.57 0.17 0.74 NOX 0.58 0.58 16.07

2007 PM10 0.17 0.17 2.44

2006 CO 0.51 0.51 4.97

2005 0.67 0.30 0.64

2004

2003 0.34 1.56 0.10 0.53 0.34 1.23

2002 2.77 6.27 0.96 2.44 2.12 3.86

2001 9.76 15.30 3.91 2.42 5.59 4.97

2000 20.83 16.07 0.92 0.66 4.35 3.73

1999 11.30 12.24 0.40 0.20 3.10 2.67

1998 13.17 2.28 2.24

SPA Wood Group Power - McClellan

Recent Permitting

Turbines Engines

Nox PM10 CO
SMAQMD Equivalency Determination for Rule 203

January 28, 2011

Page 23

CO PM10 NOX VOC SOX GHG

Facility PTE(TPY) 99 15 10 140,020

Cooling Tower

ROC Nox PM10 CO ROC Nox PM10 CO ROC Nox PM10 CO PM10 

2009 0.589 1.382 0.964 3.373 0.004 0.204 0.03 0.325 0.014 0.056 0.002 0.014 0.891

2008 0.5798026 1.1798217 0.822134 2.827048 0 0.002 0 0.003 0.0022 0.031 0.0022 0.0067

2007

2006

2005 0.5497307 2.8440997 0.782481 2.861068 0 0 0 0 0.0013 0.0191 0.0013 0.004

2004

2003 0.67 3.85 0.93 1.623 0 0 0 0 0.002 0.0279 0.002 0.006

2002 0.6213896 3.664815 0.89034 3.58838 0 0 0 0 0.0004 0.0052 0.0004 0.0004

2001 0.3 4.86 1.5 2.17 0 0.01 0 0 0 0 0 0

2000 0.360024 5.65 1.82 2.62 0 0 0 0 0.0018 0.03 0.0018 0.0056

1999 0.41637 11.05 2.13 5.44 0.01 0.48 0.04 0 0.0013 0.02 0.0013 0.004

1998 0.415789 8.14 2.08 5.3 0.01 0.48 0.04 0 0.0024 0.03 0.0024 0.0072

tons/year 2 yr ave tons/year 2 yr ave tons/year 2 yr ave 2009/10

2009 1.64 1.43 1.89 1.36 3.71 3.27

2008 1.21 0.82 2.84

2007

2006

2005 2.86 0.78 2.87

2004

2003 3.88 3.77 0.93 0.91 1.63 2.61

2002 3.67 4.27 0.89 1.20 3.59 2.88

2001 4.87 5.28 1.50 1.66 2.17 2.40 Last 2 yr 2 out of 5 2 out of 10

2000 5.68 8.62 1.82 2.00 2.63 4.03 NOX 1.43 1.43 10.10

1999 11.55 10.10 2.17 2.15 5.44 5.38 PM10 1.36 1.36 2.15

1998 8.65 2.12 5.31 CO 3.27 3.27 5.38

Increased size of boilers and added new 

engine

State of California, Department of General Services

Built new central plant

Boilers - Natural Gas Boiler - Fuel Oil IC Engine

Nox PM10 CO Recent Permitting
SMAQMD Equivalency Determination for Rule 203

January 28, 2011

Page 24

CO PM10 NOX VOC SOX GHG

Facility PTE (TPY) 453 289 84 124 2 62,141

Air Strip Coating Cold Cleaning Other SolventsAbrasive Blasting

ROG CO Nox PM10 ROG ROG ROG CO Nox PM10 ROG CO Nox PM10 ROG ROG PM10 ROG CO Nox PM10 ROG Nox

2009 0.00507809 2.5416799 0.154399 3.7561031 0.39827 4.98920176 0.495483 8.769723 6.870594 0.725563 0.116165 0.7367148 1.3332129 0.068307 0.823012 4.764993034 0.05302579

2008 0.00336568 1.6266887 0.10097 2.49060135 0.38877 4.56395899 0.410984 6.177021 6.080317 0.56671 0.04104 0.04905 0.6122 0.041187 0.027454 3.525211944 0.045430535

2007 0.00853645 3.9424901 0.256094 6.316973 0.3885 2.6515316 0.444165 8.343067 5.876507 0.677202 0.04104 0.04905 0.6122 0.041187 0.915888 1.711455 0.043303125

2006 0.00094745 0.539111 0.028424 0.701113 0.3722 4.976265 0.675687 15.11241 10.71394 1.124534 0.04104 0.04905 0.6122 0.041187 0.583125 1.8901465 0.10016631

2005 0.00279633 2.3285106 0.08389 2.0692805 0.4624 2.2115 0.321388 4.070455 4.041176 0.383342 0.621934 12.475155 1.4839 0.098756 4.29472 7.961 0.097688161

2004 0.02605188 0.2540503 0.781556 15.631125 4.27995 4.24037 0.437889 6.457465 5.68986 0.625858 0.076725 0.38 1.58 0.078178 1.02 3.409383735 0.06880745

2003 0.05 0.29076 2.15 42.92 1.3 0.99018399 0.5512 1.63 7.81 0.9 0.08 0.38 1.58 0.08 5.48718 7.252383127 0.03338795

2002 0.048902 0.29076 2.15 42.92 1.3 0.99018399 0.552769 1.63 7.81 0.9 0.075303 0.38 1.58 0.07808 5.48718 3.532383127 0.03338795

2001 0.05 0.29 2.15 42.92 1.3 1 0.55 1.63 7.81 0.9 0.08 0.38 1.58 0.08 5.49 3.53 0.03

2000 0 5.85 0.16 3.13 0.7356 8.94989 0.55456 1.793 6.46 0.96 0 0.2 0 0 2.86 0.963237 0.616 0.1

1999 0.003493 1.76 0.16 3.13 2.336 8.32121 0.610988 1.79378 6.7185 0.994768 0.015813 0.04 0.184 0.012688 5.66628 2.199715 0.573 0 0.103 0.77 15.42

1998 0.006986 97.06 0.36 7.26 12.1052 7.48862 0.995553 2.90268 10.8396 1.637468 0.055346 0.139 0.646 0.04392 3.46 0.053816 0.33548 0 0.136 1.02 20.37 2.96 0.13

tons/year 2 yr ave tons/year 2 yr ave tons/year 2 yr ave 6 -10 minor applications/year modifying or

2009 8.36 7.58 4.60 3.87 12.05 9.95 adding equipment

2008 6.79 6.77 3.14 5.11 7.85 10.09

2007 6.74 9.05 7.08 4.52 12.33 14.02

2006 11.35 8.48 1.97 2.31 15.70 17.29

2005 5.61 6.83 2.65 9.53 18.87 12.98

2004 8.05 9.80 16.40 30.17 7.09 4.70

2003 11.54 11.54 43.93 43.93 2.30 2.30

2002 11.54 11.54 43.93 43.93 2.30 2.30

2001 11.54 9.08 43.93 24.32 2.30 5.07 Last 2 yr 2 out of 5 2 out of 10

2000 6.62 7.23 4.71 12.42 7.84 5.77 NOX 7.58 9.05 11.54

1999 7.83 10.41 20.13 24.89 3.70 51.97 PM10 3.87 5.11 43.93

1998 13.00 29.65 100.24 CO 9.95 17.29 51.97

Nox PM10 CO Recent Permitting

Aerojet

Engine Testing Boilers IC Engine Open Burning Miscell
SMAQMD Equivalency Determination for Rule 203

January 28, 2011

Page 25

ATTACHMENT B

POTENTIAL PAL LIMITATIONS
SMAQMD Equivalency Determination for Rule 203

January 28, 2011

Page 26

Theoretical PAL - CO

Facility Year Actual 

Emissions (tpy)

2-year Avg 

(tpy)

Significance 

(tpy)

Theoretical PAL 

(tpy)

Permitted PTE 

(tpy)

SPA 2009 1.89 1.15 100 101.15 43.688

2008 0.40

SCA 2009 15.65 16.86 100 116.86 99.34

2008 18.07

Campbell Soup 2009 5.60 3.57 100 103.57 54.364

2008 1.54

Carson ICE 2009 66.14 71.14 100 171.14 100

2008 76.13

Cosumnes Power 2009 29.65 31.10 100 131.10 297.752

2008 32.54

UCD MED 2009 19.53 23.64 100 123.64 40.848

2008 27.75

SPA McClellan 2009 0.28 0.51 100 100.51 73.32

2008 0.74

Kiefer 2009 402.22 404.61 100 504.61 445.746

2008 407.01

DGS 2009 3.71 3.27 100 103.27 99

2008 2.84

Aerojet 2009 12.05 9.95 100 109.95 453

2008 7.85

As required by 40 CFR Part 52.21(aa)(6) the “theoretical” PAL, if requested by the source 

equals the 2 year average emissions + significance threshold for that pollutant. This analysis 

does not reduce the PAL limit by any potential regulations as there are no SMAQMD 

restrictions that will affect these pollutants. At this time, it is not possible to project c0-

benefits that may arise from the GHG Cap and Trade rules for this pollutant.
SMAQMD Equivalency Determination for Rule 203

January 28, 2011

Page 27

Theoretical PAL - NOx

Facility Year Actuals 

Emissions (TPY)

2-year 

Avg (tpy)

Significance 

(tpy)

Theoretical PAL 

(tpy)

Permitted PTE 

(tpy)

SPA 2009 28.73 34.68 40 74.68 49.9

2008 40.63

SCA 2009 26.46 35.54 40 75.54 58.767

2008 44.62

Campbell Soup 2009 0.47 0.33 40 40.33 61.98

2008 0.18

Carson ICE 2009 24.99 26.86 40 66.86 53.35

2008 28.72

Cosumnes Power 2009 62.51 64.58 40 104.58 125.6

2008 66.65

UCD MED 2009 11.54 11.27 40 51.27 21.16

2008 11.00

SPA McClellan 2009 0.59 0.58 40 40.58 24.65

2008 0.57

Kiefer 2009 69.19 73.64 40 113.64 87.5

2008 78.10

DGS 2009 1.64 1.43 40 41.43 10

2008 1.21

Aerojet 2009 8.367.58 40 47.58 84

2008 6.79

As required by 40 CFR Part 52.21(aa)(6) the “theoretical” PAL, if requested by the source 

equals the 2 year average emissions + significance threshold for that pollutant. This analysis 

does not reduce the PAL limit by any potential regulations as there are no SMAQMD 

restrictions that will affect these pollutants. At this time, it is not possible to project c0-

benefits that may arise from the GHG Cap and Trade rules for this pollutant.
SMAQMD Equivalency Determination for Rule 203

January 28, 2011

Page 28

Theoretical PAL - PM10

Facility Year 

Actual 

Emissions 

(tpy)

2-year 

Avg (tpy)

Significance 

(tpy)

Theoretical PAL 

(tpy)

Permitted PTE 

(tpy)

SPA

2009 11.56 14.89 15 29.89 22.54

2008 18.21

SCA

2009 17.38 18.07 15 33.07 58.767

2008 18.75

Campbell Soup

2009 2.39 2.22 15 17.22 7.772

2008 2.04

Carson ICE

2009 8.21 8.88 15 23.88 19

2008 9.54

Cosumnes Power

2009 33.27 31.19 15 46.19 80.2

2008 29.12

UCD MED

2009 6.48 6.40 15 21.40 12.24

2008 6.31

SPA McClellan

2009 0.17 0.17 15 15.17 10.44

2008 0.17

Kiefer

2009 14.12 15.05 15 30.05 27.1

2008 15.98

DGS

2009 1.89 1.36 15 16.36 15

2008 0.82

Aerojet

2009 4.60 3.87 15 18.87 289

2008 3.14

As required by 40 CFR Part 52.21(aa)(6) the “theoretical” PAL, if requested by the source 

equals the 2 year average emissions + significance threshold for that pollutant. This analysis 

does not reduce the PAL limit by any potential regulations as there are no SMAQMD 

restrictions that will affect these pollutants. At this time, it is not possible to project c0-

benefits that may arise from the GHG Cap and Trade rules for this pollutant.