Santa Barbara County Air Pollution Control District

STAFF REPORT – June 19, 2008

REVISIONS TO 

RULE 102. DEFINITIONS

REGULATION II. PERMITS

RULE 333. CONTROL OF EMISSIONS FROM RECIPROCATING 

INTERNAL COMBUSTION ENGINES

BACKGROUND 

The Santa Barbara County Air Pollution Control 

District (APCD) proposes modifications to Rule 201 

and Rule 202, which implement the APCD permitting 

process, and Rule 333, which specifies the 

requirements for engines. 

The APCD first required Permits to Operate for 

piston-type internal combustion engines in 1988. In 

1991, the APCD adopted Rule 333 to control 

emissions from reciprocating internal combustion 

engines. Other than a minor change to a rule 

reference in 1997, the APCD has not modified Rule 

333 from the originally adopted rule. In 1995, the 

EPA suggested changes to the engine permitting 

exemptions in Rule 202 and changes to Rule 333 to 

make the rules acceptable for inclusion into the State 

Implementation Plan. 

In 1997, the APCD adopted Rule 201 and Rule 202 

revisions as part of major revisions to Regulation II 

(Permits). That rulemaking effort included moving 

the New Source Review provisions out of Regulation

II into a new Regulation VIII (New Source Review). 

The 1997 Regulation II changes modified the 

permitting requirements for engines. Those changes 

included revising the drill rig exemption, adding an 

exemption for engines registered in the statewide 

registration program, and exempting other 

miscellaneous engines. 

The APCD did not modify Rule 333 as part of the 

1997 Regulation II changes. Thus, staff did not 

address EPA suggestions at that time. The current 

rulemaking effort includes changes to engine 

requirements in Rule 202 and Rule 333 to address the 

EPA issues.

Aside from the March 2005 Rule 202 revision to 

expand permit applicability for diesel engines for the 

implementation of the state Airborne Toxic Control 

Measure, the APCD has not modified Rule 202 since 

1997. 

PROPOSED REVISIONS

This rulemaking effort addresses all ARB-identified 

suggestions and all EPA-identified deficiencies 

regarding the permitting and control of internal 

combustion engines. These concerns, summarized in 

Appendix A, need to be addressed in order for the 

engine permitting requirements of Rule 202 and the 

Rule 333 engine requirements to be considered for 

inclusion in the State Implementation Plan.

During the rule development process, the APCD 

received requests to modify and add Rule 202 permit 

exemptions that are unrelated to the internal 

combustion engine (ICE) exemptions. The APCD

considered each request and, where suitable, included 

the new or amended exemption provision.

In the amended Rule 333 provisions, oxides of 

nitrogen (NOx), carbon monoxide (CO), and reactive 

organic compound (ROC) limits for ICEs are revised 

to meet a “Reasonably Available Control 

Technology” (RACT) level of control. The EPA 

requires that rules have, at a minimum, a RACT level 
STAFF REPORT - Regulation II/Rule 333 Page 2

June 19, 2008

Santa Barbara County APCD

of control for them to be included in the State 

Implementation Plan. 

The changes to the emission limits for spark ignition 

internal combustion engines are consistent with the 

RACT standards in the CARB Reasonably Available 

Control Technology and Best Available Retrofit 

Control Technology Determination.[1] The changes 

to the emission limits for compression ignition 

engines are based on other air district‟s RACT 

standards.[2, 3]

These rule changes demonstrate that the District's 

Clean Air Plan to attain the California ambient ozone 

standard provides for expeditious implementation of 

“every feasible measure” to reduce ozone precursor 

emissions. 

The APCD expects the proposed revisions to Rules

202 and 333 pertaining to ICEs to result in 6.5 tons 

per year of NOx emission reduction and 0.03 ton per 

year of ROC emission increase. The costeffectiveness of the Rule 333 revision is estimated to 

be between $1,550 and $11,532 per ton of NOx 

reduced. 

Key provisions of proposed amended Rule 333 are 

illustrated in flowchart format in Appendix M.

Sources that May be Affected by the 

Changes to Rule 202.F and Rule 333

The sources using an engine that may be affected by 

this rulemaking effort include, but are not limited to, 

sources performing: oil and gas exploration, 

production, processing and petroleum product 

marketing; mineral processing; construction; and 

agricultural operations subject to the APCD Part 70 

Operating Permit Program. Emergency standby 

engine requirements will not be affected by the 

proposed rule revisions.

Appendix B summarizes the known companies with 

permit-exempt engines that will become subject to 

permitting requirements due to the Rule 202.F 

revisions. Appendix C lists the known sources 

operating engines currently subject to or that will 

become subject to the Rule 333 emission limits under 

the proposed amended rules.

Rule 102, Definitions

The APCD proposes to add and modify several 

definitions that are used in various parts of the 

rulebook. 

Appendix D contains an annotated proposed amended 

Rule 102 with notes on the origin and necessity for 

each of the new and revised definitions.

Rule 201, Permits Required

The Rule 201.D.2 provisions on exempting or 

permitting pile drivers, pipe-laying barges, and 

derrick barges is relocated into Rule 202, Section F.7. 

The Rule 202.F.7 provision is expanded to include 

cable-laying and pipe-laying vessels. 

The Section D.1 alphanumerical designation is 

reduced to Section D (due to the relocation of Section 

D.2). The APCD is adding text to Rule 201, Section 

D, indicating equipment use requires an Authority to 

Construct. 

Appendix E contains an annotated proposed amended 

Rule 202 with notes on the new and revised 

provisions.

Rule 202, Exemptions to Rule 201

The APCD proposes changes to the rule to 1) delete 

the construction engine and well drilling equipment 

exemption, 2) add five new exemptions, and 

3) modify several existing exemptions. 

Appendix F contains an annotated proposed amended 

Rule 202 with notes on the new and revised 

provisions. 

Rule 333, Control of Emissions from 

Reciprocating Internal Combustion Engines

Changes to Rule 333 1) address ARB and EPA 

concerns and 2) revise the emission limits to be 

consistent with the RACT standards.

Appendix G provides an annotated proposed 

amended Rule 333 with notes on each proposed 

change. The following table provides a summary of 

the Rule 333 NOx emission limit changes.
STAFF REPORT - Regulation II/Rule 333 Page 3

June 19, 2008

Santa Barbara County APCD

SUMMARIZED OXIDES OF NITROGEN EMISSION LIMIT CHANGES 

RESULTING FROM THE PROPOSED AMENDED RULE 333

Engine Type

Rule 333 NOx 

Limits Effective 

December 3, 1991

Rule 333 NOx 

Limits Effective 

[date of revised rule 

adoption]

Effect of Rule 333 

Change

% 

Control

ppmv 

(at 15% 

O2)

% 

Control

ppmv 

(at 15% 

O2)

Rich-Burn NoncyclicallyLoaded Spark Ignition 

Engines – Category 1 

Engines

90 50 90 50 No change 

Lean-Burn Spark Ignition 

Engines in the 50 to less 

than 100 brake horsepower 

(bhp) Range – Category 2 

Engines

80 125 - 200 Increased emission 

limit

Lean-Burn Spark Ignition 

Engines Rated 100 bhp or 

Greater – Category 3 

Engines

80 125 80 125 No change

Rich-Burn CyclicallyLoaded Spark Ignition 

Engines – Category 4 

Engines

90 50 - 300 Increased emission 

limit

Compression Ignition 

Engines and Dual-Fuel 

Engines – Category 5 

Engines

- 797 40 700 Decreased 

emission limit

NOx EMISSION REDUCTION / COST-EFFECTIVENESS

The APCD identified ten engines in Santa Barbara 

County that will require the application of 

emission control techniques (or enhanced emission 

control techniques) as a result of the changes to 

Rules 202 and 333. Because emission reductions 

will occur, a discussion of the cost-effectiveness 

and incremental cost-effectiveness data follows. 

NOx Emission Reductions

Appendix H indicates the total emission reduction 

from modifying Rules 202 and 333 is 6.5 tons of 

NOx per year. 

Cost-Effectiveness

The cost-effectiveness associated with revising 

Rule 333 ranges from $1,550 to $11,532 per 

ton of NOx reduced. Appendix H includes a 

summary of the cost-effectiveness data.

Incremental Cost-Effectiveness

Health and Safety Code Section 40920.6 

requires the performance of an incremental 

cost-effectiveness analysis for a regulation 

that identifies more than one control option 

to meet the same emission reduction 

objectives. Incremental cost-effectiveness is 

defined as the difference in costs divided by 

the difference in emission reductions between 
STAFF REPORT - Regulation II/Rule 333 Page 4

June 19, 2008

Santa Barbara County APCD

one level of control and the next more stringent 

level of control. 

Rule 333 requires compliance with NOx, ROC, 

and CO emission limits. Although, the APCD 

expects the engines to be able to meet the limits 

with low-emissions tuning procedures, sources 

could replace the engine with an electric motor in 

lieu of complying with the engine exhaust 

limits. The incremental cost-effectiveness 

between the low-emissions tuning procedure 

and electrification is assessed to be $479 per 

ton of NOx reduced. Appendix H also 

includes a summary of the incremental costeffectiveness data.

ENVIRONMENTAL IMPACTS OF METHODS OF COMPLIANCE / CEQA 

Methods of Compliance 

California Public Resources Code § 21159 

requires the APCD to perform an environmental 

analysis of the reasonably foreseeable methods of 

compliance if the proposed rule requires “the 

installation of pollution control equipment, or 

[specifies] a performance standard or treatment 

requirement...” The proposed revisions to Rule 

333 specify revised performance standards. Many 

existing sources already comply with the proposed 

revisions by performing low emissions tuning or 

using either clean burn kits for lean-burn engines 

or selective catalytic convertors for rich-burn 

engines. These are the most reasonably 

foreseeable methods of compliance. 

CEQA Requirements

Pursuant to the California Environmental 

Quality Act (CEQA) Guidelines Section 

15070 and the APCD Environmental Review 

Guidelines, adopted in October 1995 and 

revised in November 2000, the Technology 

and Environmental Assessment Division of the 

APCD prepared a Negative Declaration for the 

implementation of revised APCD Rules 102 

(Definitions), 201 (Permits Required), 202 

(Exemptions to Rule 201), and 333 (Control of 

Emissions from Reciprocating Internal 

Combustion Engines). 

The proposed Negative Declaration was 

circulated for public review for a period of 30 

days from May 12, 2008 to June 12, 2008.

ANALYSIS OF EXISTING FEDERAL AND DISTRICT REGULATIONS

Appendix I contains the written analysis required by the California Health & Safety Code Section 40727.2 

requirements. 

COMMENTS AND PUBLIC MEETINGS 

Comments

Appendix J contains the comments received in 

response to the workshops and stakeholder meetings. 

Appendix J also contains the APCD‟s responses to 

the comments.

Meetings

PUBLIC WORKSHOP, DECEMBER 8, 2005

Industry representatives had concerns on the 

proposed revisions to the definitions, permitting 

requirements, and the engine provisions. There were 

also concerns on the proposed stacking provisions 

and other nuances of the APCD permitting and 

enforcement processes.
STAFF REPORT - Regulation II/Rule 333 Page 5

June 19, 2008

Santa Barbara County APCD

WSPA STAKEHOLDERS‟ MEETING, MARCH 3, 

2006

WSPA met with APCD personnel and discussed 

several concerns. These included the loss of the 

construction equipment and well drilling equipment 

exemptions and requiring emission offsets for such 

short term projects. Also, there was discussion on 

requirements for continuous emissions monitors, 

source testing averaging times, engine modes during 

testing, and routine engine monitoring (quarterly vs. 

monthly).

STAKEHOLDERS‟ MEETING, JANUARY 25, 

2007

The APCD released revised proposed amended rules 

to the public on December 15, 2006. To get industry 

feedback on the latest proposed amended rules, the 

APCD met with stakeholders on January 25, 2007. 

During the meeting, the group discussed rule revision 

issues and the progress being made to resolve them. 

EXXONMOBIL MEETING, JUNE 12, 2007

Staff met with ExxonMobil representatives and 

discussed concerns about the proposed revised rules. 

Many of the concerns were the same ones raised 

earlier by WSPA (e.g., loss of the well drilling 

equipment exemption, the construction equipment 

exemption, and offset requirements). The discussion 

included information on the past, current, and future 

Santa Ynez Unit Project construction and operations.

VANDENBERG AIR FORCE BASE MEETING, 

JUNE 14, 2007

The VAFB representatives presented their concerns 

on construction emissions, equipment emissions (i.e., 

the handling of construction emissions associated 

with non-permitted structures and infrastructure-type 

utility pipelines and power lines), the treatment of 

marine vessel emissions when they are associated 

with VAFB, microturbines used for backup 

distributed generation, and the 55 gallons per year 

exemptions (e.g., Rule 202.I.3, coatings application 

equipment exemption, and Rule 202.U.3, solvent 

wipe cleaning exemption). 

PUBLIC WORKSHOP, FEBRUARY 13, 2008

The regulated community indicated that they 

generally appreciated the newly proposed permit 

exemptions. Further, the new exemptions addressed 

many of the industry‟s concerns stemming from the 

deletion of the well drilling and construction 

equipment exemptions. However, they provided 

suggestions on additional changes to the exemptions 

provisions, clarification of existing exemptions, 

revisions to the Background Paper, and possible 

revisions to the APCD permitting program to avoid 

new source review for short-term projects. They also 

expressed a concern about possible CEQA 

implications (e.g., emissions mitigation) if the APCD 

grants a permit or an exemption under one of the new 

provisions (Rule 202.F.7, 202.F.8, or Rule 202.P.14).

The APCD answered questions, addressed some of 

the concerns and agreed to research and/or give 

further consideration to other concerns, requests, and 

suggestions. 

On proposed amended Rule 202.F.1.f, industry would 

prefer that the APCD not require permits for spark 

ignition engines rated less than 50 bhp. Staff 

explained that there would be a rule relaxation issue 

(New Source Review provisions) and Part 70 

Operating Permit provisions if the APCD eliminated 

the existing permit requirements for engines rated less 

than 50 bhp. However, to alleviate some the concern, 

the APCD has agreed to revise the proposed 

threshold from 250 bhp to 400 bhp (based on the 

distribution of engines). The proposed range of the 

engine bhp ratings will remain the same: greater than 

20 through less than 50 bhp.

Regarding the CEQA implications, the APCD 

anticipates being able to address these through the 

rulemaking process, thereby simplifying projectspecific CEQA analyses associated with the Rule 202 

provisions.

APCD staff confirmed that past alternative methods 

for determining fuel usage for an engine without a 

dedicated fuel meter will continue to be acceptable 

(e.g., methods that take into account the individual 

engine operating hours, brake specific fuel 

consumption ratings and bhp ratings, and the fuel‟s 

higher heating value).
STAFF REPORT - Regulation II/Rule 333 Page 6

June 19, 2008

Santa Barbara County APCD

COMMUNITY ADVISORY COUNCIL MEETING, 

APRIL 23, 2008

The Community Advisory Council (CAC) 

recommended that the staff report include 

clarifications on the emissions offset requirements 

and the use of the temporary equipment exemption. 

With incorporation of those clarifications, the CAC 

passed a motion to recommend that the Board 

approve the proposed amended rules. Staff has 

provided these clarifications in Attachment N, 

Frequently Asked Questions.

PUBLIC HEARING ON THE ADOPTION OF THE 

PROPOSED AMENDED RULES, JUNE 19, 2008

The Board is scheduled to consider the adoption of 

the revised rules at the June 19, 2008 Public Hearing.

COMPARISON OF ADJOINING APCD RULES

Appendix K provides a comparison of the San Joaquin Valley APCD, Ventura County APCD, and the San Luis 

Obispo County APCD rules on permit exemptions and requirements for internal combustion engines. Basically, 

there are general similarities with some minor differences between the adjoining air district rules and the proposed 

amended rules. 

IMPACTS OF THE REVISED RULES TO INDUSTRY AND THE APCD

Details of the impacts from the rule revisions are summarized in Appendix L. The rule revisions will cause impacts

to the regulated community and APCD staff by:

1. Eighty-nine previously exempt engines becoming subject to permitting (new applications). 

2. Eleven engines becoming subject to Rule 333 emission limits for the first time.

3. Ten engines requiring an emission control technique or use of an enhanced emission control technique 

(modification applications for engines listed in Appendix H, Table 1).

4. The requirement to submit new and revised Inspection and Maintenance Plans and Compliance Plans.

5. The initial and subsequent source testing of engines to demonstrate compliance with a new or revised 

emission limit.

6. Applying and verifying control techniques to comply with the Rule 333 emission limits. 

7. New or increased operating and monitoring costs.

8. New or increased fees associated with permitting, source testing, annual emissions, air quality plans, and the 

air toxics program. 

9. Equipment owners or operators seeking exemptions under the new specialty equipment, gas turbine, or 

winery exemption provisions.

RULE CLARIFICATION ISSUES

During public workshops and meetings, members of the regulated community raised concerns and questions about 

the intent of certain rule provisions. These are addressed in the public comment section (Appendix J) and the 

Frequently Asked Questions (Appendix N).
STAFF REPORT - Regulation II/Rule 333 Page 7

June 19, 2008

Santa Barbara County APCD

REFERENCES 

1. Air Resources Board, Determination of 

Reasonably Available Control Technology and 

Best Available Retrofit Control Technology for 

Stationary Spark-Ignited Internal Combustion 

Engines, November 1991.

2. Sacramento Metropolitan Air Quality 

Management District, Rule 412, Stationary 

Internal Combustion Engines Located at Major 

Stationary Sources of NOx, June 1, 1995.

3. Ventura County Air Pollution Control District, 

Rule 74.9, Stationary Internal Combustion 

Engines, November 8, 2005.

APPENDICES

Appendix A: EPA and ARB Concerns on Rules 202 and 333 (Pursuant to Documents Dating from 1992 and 1994)

Appendix B: Known Companies with Permit-Exempt Engines that will Become Subject to Permitting Due to 

Revisions to Rule 202

Appendix C: Known Sources Currently Operating Engines Subject to or that will Become Subject to Rule 333 

Emission Limits

Appendix D: Annotated Proposed Amended Rule 102, Definitions

Appendix E: Annotated Proposed Amended Rule 201, Permits Required

Appendix F: Annotated Proposed Amended Rule 202, Exemptions to Rule 201

Appendix G: Annotated Proposed Amended Rule 333, Control of Emissions from Reciprocating Internal 

Combustion Engines

Appendix H: Summarized Data on Emission Reductions, Cost-Effectiveness, and Incremental Cost-Effectiveness

Appendix I: Identification of Existing Federal and APCD Regulations that Apply to the Same Equipment or Source 

Type Covered in Rule 333

Appendix J: Public Comments and the APCD Responses

Appendix K: Comparison of the Proposed Amended Rules to the Rules in the Adjoining Air Districts

Appendix L: Impacts of the Revised Rules to Industry and the APCD

Appendix M: Flowchart Overviews of Proposed Amended Rule 333 Provisions on Applicability; Engine 

Identification, Meters, and Continuous Monitoring Systems; Emission Limits; and Compliance 

Schedule

Appendix N: Frequently Asked Questions
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STAFF REPORT - Regulation II/Rule 333 Page A-1

June 19, 2008

Appendix A

Santa Barbara County

EPA and CARB Concerns on Rules 202 and 333 (Pursuant to Documents Dating from 1992 and 1994)

REFERENCE -

AGENCY/LETTER

CATEGORY 

OF CONCERN SECTION No. CONCERNa COMMENT

CARB Letter of 

March 6, 1992, Item 

1

Rule 

Improvement 

Issue

D.3, Emission 

Limits for Cyclic 

Engines

In Section D.3, the requirements for cyclic engines are 

unclear. Section D.3.a requires at least 6.5% oxygen in 

exhaust at all times and prescribes a source testing 

schedule. Section D.3.b additionally requires 

compliance with emissions limits for NOx, ROC, and 

CO. However, Section D.3.c states that, instead of 

complying with Section D.3.a and D.3.b, the engine 

can be declared noncyclic and the owner or operator 

can comply with Section D.1. Section D.1 specifies 

emission limits for "noncyclic rich burn engines," 

which are identical to those specified in Section D.3.b 

for cyclic engines. The effect of Section D.3.c seems 

to be to make compliance with Section D.3.a entirely 

optional, but this may not be the intent of the District. 

It is also unclear whether the District intends that 

cyclic engines arbitrarily designated "noncyclic" be 

required to operate in "rich burn" mode, e.g., with 

oxygen below 4% in their exhaust. This section should 

be changed to clarify the District's intent.

Another point of confusion is the reference in Section 

D.3.b to Section I. Section I.3.b seems to indicate that 

the District will decide within a year of adoption 

whether emission limits in Section D.3.b (or some 

other limits) are to be applied or not. If emission limits 

are to be set subsequent to rule adoption, it would be 

clearer to specify only emission limits which must be 

complied with immediately or, if no current limits 

apply, to indicate that emission limits may be imposed 

in the future and to describe the period which will be 

allowed for compliance once they are imposed.

Under the proposed amended Rule (PAR) 333, Section 

D.3 becomes Section E.3. Staff has deleted references 

to the requirement to maintain the 6.5% oxygen in the 

exhaust stream and source tests from this section. The 

proposed revisions to the definitions of lean-burn and 

rich-burn engine should prevent sources from changing 

the status of a rich-burn engine to be a lean-burn engine 

without obtaining a District approval.

The optional Section D.3.c is deleted in the PAR. The 

revised rule provisions and the new cyclically-loaded 

engine definition do not provide an option for 

owners/operators to declare a cyclic engine to be a 

noncyclic engine.

On March 2, 1993, the Air Pollution Control District 

Board of Directors held a public hearing to review 

additional information pertaining to the requirements of 

Section D. Industry did not provide any information on 

the emission limits at that time. Thus, no changes to 

the spark ignition emission limits were made and 

sources needed to be in full compliance with the Rule 

by March 3, 1994.

 

a These are verbatim from the referenced document.
STAFF REPORT - Regulation II/Rule 333 Page A-2

June 19, 2008

REFERENCE -

AGENCY/LETTER

CATEGORY 

OF CONCERN SECTION No. CONCERNa COMMENT

CARB Letter of 

March 6, 1992, Item 

2

Rule 

Improvement 

Issue

D.4, Emission 

Limits for Diesel 

Engines

Section D.4 specifies somewhat higher NOx limits for 

diesel engines than permitted in Sections D.1. or D.2, 

but does not indicate whether the emission limits for 

ROC and CO specified in those sections apply to diesel 

engines. The limits for ROC and CO emissions for 

diesel engines should be clearly indicated and, if none 

are to be imposed, this should be stated explicitly.

The Rule 333, Sections D.1 and D.2 limits were not 

intended to apply to compression ignition engines. 

Further, the diesel engine emission limits in Rule 333, 

Section D.4, only limited NOx emissions. 

Consistent with RACT requirements, the PAR 333 

includes NOx, ROC, and CO emission limits for diesel 

engines. The text has been revised to clarify the 

applicable emission limits for the different engine 

classifications.

CARB Letter of 

March 6, 1992, Item 

3

Rule 

Improvement 

Issue

G.3.a, 

Requirements -

Testing, Test 

Methods

In Section G.3.a, the reference to "CARB Method 1-

100" should be corrected to reference "CARB Method 

100."

In addition, the reference to "EPA Method 18 or EPA 

Method 25" should be changed to "EPA Method 25 for 

determination of total organics and EPA Method 18 for 

determination of exempt compounds," since the 

methods are not alternatives but are rather used in 

combination to determine ROC corrected for exempts.

The change to CARB Method 100 is reflected in the 

revised rule. Consistent with the CARB Spark-Ignited 

Engine RACT/BARCT determination, the draft rule 

includes references to the EPA methods.

For ROC testing, our source testing staff prefers that 

the rule stipulate only the EPA method 18 with gas 

chromatography-flame ionization detection speciation 

analysis for C1, C2, C3, C4, C5, C6+ species.

EPA Notice of 

Proposed 

Rulemaking, 

Technical Support 

Document, November 

1994, Item 1

Rule 

Deficiency

Section A,B 

Applicability/ 

Exemptions

Rule 333 applies to units with a rated brake 

horsepower of 50 or greater. Although Rule 333 is 

written as applicable to these size engines, 

SBCAPCD's Rule 202, which includes exemptions 

from permit requirements, exempts units rated below 

100 brake horsepower. Rule 333 allows exemptions for 

units exempt from permit requirements. SBCAPCD 

has agreed to modify Rule 202 to ensure consistency 

with Rule 333. Therefore, the exemption provision in 

section B.1.b of Rule 333 should be deleted.

Providing a prohibitory rule exemption for permitexempt equipment is a common practice (e.g., Rule 

342.B.1.d). With the lowering of the single-engine 

permitting threshold to 50 bhp in Rule 202, the 

“consistency issue” will be eliminated. Thus, the Rule 

333.B.1.b provision shall be maintained.
STAFF REPORT - Regulation II/Rule 333 Page A-3

June 19, 2008

REFERENCE -

AGENCY/LETTER

CATEGORY 

OF CONCERN SECTION No. CONCERNa COMMENT

EPA Notice of 

Proposed 

Rulemaking, 

Technical Support 

Document, November 

1994, Item 2

Rule 

Deficiency

Section C, 

Definitions

The definition of "rated brake horsepower" is specified 

as the maximum revolutions per minute specified by 

the manufacturer. The definition also allows an 

"alternative" bhp rating to be set by a district-issued 

permit to operate. Under this alternative rating, 

engines can be operated at different levels such as 

maximum rating, continuous rating, or derated. Since 

engine ratings are crucial for determining rule 

applicability, the provision in this section allowing 

alternative ratings should be deleted. EPA believes the 

definition should specify rating as output determined 

by the manufacturer and listed on the nameplate, 

regardless of any derating.

The revised rated brake horsepower definition, 

proposed to be moved to Rule 102, is similar to the San 

Joaquin Valley Unified APCD (SJV) Rule 4701 and 

Rule 4702 definitions. EPA approved those SJV rules 

into the SIP on May 18, 2004 (69 FR 28061). Thus, 

the Santa Barbara County APCD does not anticipate 

that EPA will identify the engine derating component 

of the definition to be a future rule deficiency.

EPA Notice of 

Proposed 

Rulemaking, 

Technical Support 

Document, November 

1994, Item 3

Rule 

Deficiency

Section D.2 and 

D.4, Emission 

Limit 

Requirements

The provision specifying emission limits for diesel 

engines requires a limit of 8.4 g/bhp-hour be met. The 

corresponding concentration limit given as corrected to 

15% oxygen is 797 ppm. These limits do not 

correspond to one another. 8.4 g/bhp-hr converts to 

approximately 670 ppm assuming 35% efficiency. 

Due to the discrepancy, the rule allows the least 

stringent (797 ppm) limit to be met. This limit should 

be corrected to reflect the RACT level of 8.4 g/bhp-hr.

According to the definition given for lean-burn 

engines, (which includes diesel engines) it is unclear if 

diesel engines must comply with the 125 ppm limit 

given for lean burn engines or the 797 ppm limit. The 

rule should distinguish between lean burn and diesel 

engines so as not to cause ambiguity in which emission 

limits are applicable.

For compression ignition engines, the PAR 333 limits 

NOx to 700 ppmv at 15% O2 limit or, when using 

exhaust controls, a minimum 40% reduction. These 

limits are being proposed to meet a RACT level of 

control. 

Regarding the ambiguities on the engine definitions and 

the rule limits, the following changes are being made: 

1) The Rule 333 definition of diesel engine is being 

moved to Rule 102 and it is being modified. 

2) PAR 102 includes new definitions for compression 

ignition engine, dual-fuel engine, and spark ignition 

engine.

3) PAR 333 includes new definitions for air-balanced 

pumping engine, beam-balanced pumping engine, 

crank-balanced pumping engine, four-stroke engine

and stoichiometric air-to-fuel ratio.

4) PAR 333 includes modified definitions of

cyclically-loaded engine, lean-burn engine, 

noncyclically-loaded engine, rich-burn engine, and

two-stroke engine. 

3) PAR 333, Section E, uses specific engine 

classification terms, when setting emission limits.
STAFF REPORT - Regulation II/Rule 333 Page A-4

June 19, 2008

REFERENCE -

AGENCY/LETTER

CATEGORY 

OF CONCERN SECTION No. CONCERNa COMMENT

EPA Notice of 

Proposed 

Rulemaking, 

Technical Support 

Document, November 

1994, Item 4

Rule 

Deficiency

Section D.5, 

Emission Limit 

Requirements

Generally, alternative emission control plans (AECPs) 

are not approvable in rules unless the provisions meet 

the requirements of EPA's Emission Trading Policy 

Statement (ETPS) and Economic Incentive Program 

(EIP) requirementsb. Rule 333 requires that AECPs 

must be submitted to SBCAPCD by March 9, 1992 and

approved by the Control Officer, ARB, and EPA. 

There have been no AECPs submitted or approved and 

the option for submitting AECPs has expired. Thus, 

EPA is not evaluating this provision for approvability 

with the ETPS/EIP and does not consider it in this case 

a rule deficiency since it is no longer applicable. 

However it is recommended that these provisions be 

deleted.

PAR 333 does not include an alternative emission 

control provision.

EPA Notice of 

Proposed 

Rulemaking, 

Technical Support 

Document, November 

1994, Item 5

Rule 

Deficiency

Section I, 

Compliance 

Schedule

Owners/operators of cyclic engines are allowed to 

comply with less stringent emission limits established 

by the Santa Barbara County Board of Supervisors 

through their public hearing process. This provision is 

intended to take into account additional information of 

a study proposed by industry to test the feasibility of 

the current rule emission limits in effect in Ventura 

County. Since no alternative limits were considered or 

established by the district's Board of Directors pursuant 

to section I.3., this provision is no longer applicable. 

However, it is recommended that these provisions by 

deleted. 

On March 2, 1993, the Air Pollution Control District 

Board of Directors held a public hearing, but industry 

did not provide any information on the emission limits. 

Thus, no changes to the spark ignition emission limits 

were made and sources needed to be in full compliance 

with the Rule by March 3, 1994. The PAR 333 will 

delete the Section I.3 provisions.

It is our understanding that compliance with the 

VCAPCD Rule was, for the most part, accomplished by 

electrification.

 

b The ETPS was published on December 4, 1986 in 51 FR 43814 and the EIP was published April 7, 1994 in 59 FR 16690 and 40 CFR Part 51, Subpart U, 51.490-

51.494.
STAFF REPORT - Regulation II/Rule 333 Page B-1

June 19, 2008

Santa Barbara County APCD

Appendix B

Santa Barbara County 

Known Companies with Permit-Exempt Engines 

That will Become Subject to Permitting due to Revisions to Rule 202a

Company Name 

(Stationary 

Source 

Identification No.)

Facility Name Fac. 

No.

Equipment 

Description

Permit Category

Size > 20 

bhp but < 

50 bhp with 

> 400 bhp 

Aggregate 

(202.F.1.f)

Derated 

ICEs 

(202.F.1.f)

Size ≥ 50 

bhp but < 

100 bhp 

(202.F.1.f)

Well 

Drilling 

(Deleted 

202.F.6)

B.E. Conway Energy, 

Inc. (SSID 1944)

Magenheimer 

Leases (A, B, C) 01946 1 Engine, DID No. 009094. X

Catco Energy (SSID 

1510)

Tognazzini Lease 

(Catco) 03200

15 Engines, DID No. 

002367, 002368, 002373, 

002374, 002378, 002379, 

002380, 002381, 002382, 

002385, 002388, 002389, 

002390, 002392, & 

002393.

X

Catco Energy (SSID 

1510)

Tognazzini Lease 

(Catco) 03200

3 Engines, DID No. 

002375, 002383, & 

002414.

X 

Elysium Russell, LLC 

(SSID 4639)

Russell Ranch 

Lease 01086

11 Engines, DID No. 

006265, 006268, 006269, 

006271, 006272, 006723, 

006274, 006279, 006281, 

006282, & 006283.

X

Elysium Russell, LLC 

(SSID 4639)

Russell Ranch 

Lease 01086

5 Engines, DID No. 

006262, 006275, 006276, 

006277, & 006290.

X

ExxonMobil Production 

Company (SSID 1482) Platform Harmony 08018 1 Engine, DID No. 005346. X

ExxonMobil Production 

Company (SSID 1482) Platform Heritage 08019 1 Engine, DID No. 005370. X

Greka Oil & Gas, Inc. 

(SSID 5032) Texas Lease 03327 1 Engine, DID No. 003155. X 

Greka Oil & Gas, Inc. 

(SSID 2680)

Gato Ridge IC 

Engines (located at 

the Williams 

Holding Lease, FID 

3512)

04215

5 Engines, DID No. 

005203, 005204, 005205, 

002506, & 005207.

X

Greka Oil & Gas, Inc. 

(SSID 2680) b

Gato Ridge IC 

Engines

04215 1 Engine, DID No. 004439. X

Greka Oil & Gas, Inc. 

(SSID 2200) Jim Hopkins Lease 03092

9 Engines, DID No. 

002106, 002107, 002108, 

002109, 002110, 002111, 

002112, 002114, & 

002115.

X

Greka Oil & Gas, Inc. 

(SSID 8678)

Los Flores IC 

Engines (Vintage) 01848

10 Engines, DID No. 

001258, 001260, 001261, 

001262, 001266, 001267, 

001269, 001270, 001273, 

& 008524.

X

 

a Unless otherwise specified, the data is based on the 2005 Inventory. There may be additional engines subject to 

permitting that the APCD is unaware of.
STAFF REPORT - Regulation II/Rule 333 Page B-2

June 19, 2008

Santa Barbara County APCD

Company Name 

(Stationary 

Source 

Identification No.)

Facility Name Fac. 

No.

Equipment 

Description

Permit Category

Size > 20 

bhp but < 

50 bhp with 

> 400 bhp 

Aggregate 

(202.F.1.f)

Derated 

ICEs 

(202.F.1.f)

Size ≥ 50 

bhp but < 

100 bhp 

(202.F.1.f)

Well 

Drilling 

(Deleted 

202.F.6)

Greka Oil & Gas, Inc. 

(SSID 8675)

SMV East IC 

Engines 04212

7 Engines, DID No. 

004223, 004231, 004233, 

004236, 004237, 004239, 

& 004241.

X

Greka Oil & Gas, Inc. 

(SSID 8702)

Zaca Area IC 

Engines 04005

4 Engines, DID No. 

003594, 003595, 003596, 

& 003603.

X 

Pacific Operators 

Offshore, Inc. (SSID 

8001)

Platform Hogan 08001 1 Engine. DID No. 007107. X

Pacific Operators 

Offshore, Inc. (SSID 

8001)

Platform Houchin 08002 1 Engine. DID No. 007108. X

Purisima Hills LLC 

(SSID 1153) H.P. Boyne Lease 03777

6 Engines, DID No. 

005908, 005909, 005910, 

005911, 005912, & 

009015.

X

Santa Maria Refining 

Company (SSID 3730) Armelin Lease 03736

4 Engines, DID No. 

005947, 005949, 005950, 

& 006231.

X

Venoco, Inc. (SSID 

1063) Platform Holly 03105

3 Engines, DID No. 

009130, 009131, & 

009132.

X

 TOTALS BY CATEGORY 26 40 16 7

OVERALL TOTAL 89
STAFF REPORT - Regulation II/Rule 333 Page C-1

June 19, 2008

Santa Barbara County APCD

Appendix C

Santa Barbara County 

Known Sources Operating Engines Currently Subject to or 

That will Become Subject to Rule 333 Emission Limits 

When the Proposed Amended Rules are Adopteda

Company Name, Stationary 

Source Description, and 

Facility Description

Stat. 

Source 

No.

Fac.

No.

Device 

No. Device Name Bhp

ICE Will Become 

Subject to the 

Emission Limits 

for the 1st time 

due to the Rule 

Revisionsb

BreitBurn Energy Company LP, 

BreitBurn Energy- Orcutt Hill, 

Orcutt Hill IC Engines

02667 04214 004434 IC Engine: (#19766) 400

BreitBurn Energy Company LP, 

BreitBurn Energy- Orcutt Hill, 

Orcutt Hill IC Engines

02667 04214 004435 IC Engine: (#12163) 

Fox Injection 301

City of Lompoc, City of Lompoc 

- WWT Plant, Lompoc WWT 

Plant

01708 01708 001192 IC Engine: Air 

Compressor 275

City of Lompoc, City of Lompoc 

- WWT Plant, Lompoc WWT 

Plant

01708 01708 001193 IC Engine: Air 

Compressor 275

City of Lompoc, City of Lompoc 

- WWT Plant, Lompoc WWT 

Plant

01708 01708 001194 IC Engine: Air 

Compressor

275

DCOR, LLC, Platform Habitat, 

Platform Habitat 08012 08012 004972 IC Engine: South Crane 128

DCOR, LLC, Platform Habitat, 

Platform Habitat 08012 08012 004973 IC Engine: North Crane 350

DCOR, LLC, Platform Habitat, 

Platform Habitat 08012 08012 004985 IC Engine: Compressor IC Engine 1350

DCOR, LLC, South County/Dos 

Cuadras, Platform A 08003 08003 004872 IC Engine: South Crane 109

DCOR, LLC, South County/Dos 

Cuadras, Platform A 08003 08003 004873 IC Engine: North Crane 230

DCOR, LLC, South County/Dos 

Cuadras, Platform B 08003 08004 004886

IC Engine: 15-Ton 

Pedestal Crane (South 

Crane)

109

DCOR, LLC, South County/Dos 

Cuadras, Platform B 08003 08004 004887

IC Engine: 25-Ton 

Pedestal Crane (North 

Crane)

230

DCOR, LLC, South County/Dos

Cuadras, Platform Hillhouse 08003 08005 004905 IC Engine: 25-Ton Pedestal (North) Crane 238

DCOR, LLC, South County/Dos 

Cuadras, Platform C 08003 08006 004924

IC Engine: 25-Ton 

Pedestal Crane (North 

Crane)

230

 

a Based on the APCD 2005 Emission Inventory.

b An “X” is shown for engines becoming subject to Rule 333 emission limits for the first time. If no “X” appears, the 

engine is already subject to Rule 333 emission limits.
STAFF REPORT - Regulation II/Rule 333 Page C-2

June 19, 2008

Santa Barbara County APCD

Company Name, Stationary 

Source Description, and 

Facility Description

Stat. 

Source 

No.

Fac.

No.

Device 

No. Device Name Bhp

ICE Will Become 

Subject to the 

Emission Limits 

for the 1st time 

due to the Rule 

Revisionsb

DCOR, LLC, South County/Dos 

Cuadras, Platform Henry 08003 08007 004939 IC Engine: 25-Ton Pedestal (North Crane) 475

E & B Natural Resources Mgt. 

Corp., E & B - South Cuyama, E 

& B IC Engines

01073 08916 006388 IC Engine: W-2 195

E & B Natural Resources Mgt. 

Corp., E & B - South Cuyama, E

& B IC Engines

01073 08916 006389 IC Engine: W-3 195

E & B Natural Resources Mgt. 

Corp., E & B - South Cuyama, E 

& B IC Engines

01073 08916 006390 IC Engine: W-8 195

E & B Natural Resources Mgt. 

Corp., E & B - South Cuyama, E 

& B IC Engines

01073 08916 006391 IC Engine: W-4 195

E & B Natural Resources Mgt. 

Corp., E & B - South Cuyama, E 

& B IC Engines

01073 08916 006392

IC Engine: W-12 

Wastewater Inj, (added 

by dfg)

195

E & B Natural Resources Mgt. 

Corp., E & B - South Cuyama, E 

& B IC Engines

01073 08916 006393 IC Engine: W-11 195

E & B Natural Resources Mgt. 

Corp., E & B - South Cuyama, E 

& B IC Engines

01073 08916 006394 IC Engine: W-15 195

E & B Natural Resources Mgt. 

Corp., E & B - South Cuyama, E 

& B IC Engines

01073 08916 006395

IC Engine: W-42 

Wastewater Inj, (added 

by dfg)

195

E & B Natural Resources Mgt. 

Corp., E & B - South Cuyama, E 

& B IC Engines

01073 08916 006396

IC Engine: B-5 

Wastewater Inj, (added 

by dfg)

135

E & B Natural Resources Mgt. 

Corp., E & B - South Cuyama, E 

& B IC Engines

01073 08916 006397 IC Engine: B-6 174

E & B Natural Resources Mgt. 

Corp., E & B - South Cuyama, E 

& B IC Engines

01073 08916 006400 IC Engine: HRA #9 

(not on PTO 8010) 792

E & B Natural Resources Mgt. 

Corp., E & B - South Cuyama, E 

& B IC Engines

01073 08916 006401 IC Engine: HRA #10 

(not on PTO 8010) 792

E & B Natural Resources Mgt. 

Corp., E & B - South Cuyama, E 

& B IC Engines

01073 08916 006402 IC Engine: HRA #11 792

E & B Natural Resources Mgt. 

Corp., E & B - South Cuyama, E 

& B IC Engines

01073 08916 006403 IC Engine: HRA #12 

(not on PTO 8010) 792

ExxonMobil Production 

Company, Exxon - SYU Project, 

Platform Hondo

01482 08009 004956 IC Engine: Pedestal 

Crane West 160
STAFF REPORT - Regulation II/Rule 333 Page C-3

June 19, 2008

Santa Barbara County APCD

Company Name, Stationary 

Source Description, and 

Facility Description

Stat. 

Source 

No.

Fac.

No.

Device 

No. Device Name Bhp

ICE Will Become 

Subject to the 

Emission Limits 

for the 1st time 

due to the Rule 

Revisionsb

ExxonMobil Production 

Company, Exxon - SYU Project, 

Platform Hondo

01482 08009 004957 IC Engine: Pedestal 

Crane East 160

ExxonMobil Production 

Company, Exxon - SYU Project, 

Platform Harmony

01482 08018 005326 Pedestal Crane East 450

ExxonMobil Production 

Company, Exxon - SYU Project, 

Platform Heritage

01482 08019 005350 Pedestal Crane East 450

Greka Oil & Gas, Inc., Cat 

Canyon, Cat Canyon IC Engines 02658 03831 006466

Controlled IC Engine 

12253 Gas 

Compressor (added by 

dfg)

225

Greka Oil & Gas, Inc., Cat 

Canyon, Cat Canyon IC Engines 02658 03831 006467

Controlled IC Engine: 

Waukesha 110007 

(Inj. #2 - added by 

dfg)

190

Greka Oil & Gas, Inc., Cat 

Canyon, Cat Canyon IC Engines 02658 03831 006468

IC Engine: #20 6LRZ 

(#912330) (NSCR) 

(Not found in PTO 

8036)

410

Greka Oil & Gas, Inc., Cat

Canyon, Cat Canyon IC Engines 02658 03831 007289

IC Engine: 

Compressor #1: 

#F3521GSI (last used 

in 2002, removed from 

permit in 2004)

747

Greka Oil & Gas, Inc., Clark 

Avenue Source, Clark Avenue IC 

Engines

02200 04204 004178 IC Engine: #912330 186

Greka Oil & Gas, Inc., Clark 

Avenue Source, Clark Avenue IC 

Engines

02200 04204 004179 IC Engine: #912331 186

Lash Construction, Lash Const. 

(5 S. Calle Cesar Chavez ), Lash 

Const. (5 S. Calle Cesar Chavez )

10309 10437

010082 

or 

107679

Diesel IC Engine (may 

be superseded by DID 

107679)

434.5

Mafi-Trench Corporation, MafiTrench, Mafi-Trench 01717 01717 001195 IC Engine: Air 

Compressor 456

Pacific Operators Offshore, LLC, 

Pacific Operators - Carpinteria, 

Platform Hogan

08001 08001 004849 IC Engine: North 

Crane 230

Pacific Operators Offshore, LLC, 

Pacific Operators - Carpinteria, 

Platform Houchin

08001 08002 004861 IC Engine: North 

Crane 230

Pacific Operators Offshore, LLC, 

Pacific Operators - Carpinteria, 

Platform Hogan

08001 08001 007107 IC Engine: Well 

Service Rig 400 X
STAFF REPORT - Regulation II/Rule 333 Page C-4

June 19, 2008

Santa Barbara County APCD

Company Name, Stationary 

Source Description, and 

Facility Description

Stat. 

Source 

No.

Fac.

No.

Device 

No. Device Name Bhp

ICE Will Become 

Subject to the 

Emission Limits 

for the 1st time 

due to the Rule 

Revisionsb

Pacific Operators Offshore, LLC, 

Pacific Operators - Carpinteria, 

Platform Houchin

08001 08002 007108 IC Engine: Well 

Service Rig 400 X

Plains Exploration & Production 

Company, Pt. Pedernales/Lompoc 

Oil Fields, Platform Irene

04632 08016 005082 IC Engine: North 

Crane 210

Plains Exploration & Production 

Company, Pt. Pedernales/Lompoc 

Oil Fields, Platform Irene

04632 08016 005083 IC Engine: South 

Crane 197

Purisima Hills LLC - Barham 

Ranch, H.P. Boyne Lease 01153 03777 005908 IC Engine: Well Pump 65 X

Purisima Hills LLC - Barham 

Ranch, H.P. Boyne Lease 01153 03777 005909 IC Engine: Well Pump 65 X

Purisima Hills LLC - Barham 

Ranch, H.P. Boyne Lease 01153 03777 005910 IC Engine: Well Pump 65 X

Purisima Hills LLC - Barham 

Ranch, H.P. Boyne Lease 01153 03777 005911 IC Engine: Well Pump 65 X

Purisima Hills LLC - Barham 

Ranch, H.P. Boyne Lease 01153 03777 005912 IC Engine: Well Pump 65 X

Purisima Hills LLC - Barham 

Ranch, H.P. Boyne Lease 01153 03777 009015 IC Engine: Natural Gas-Fired 65 X

SBC Resource Recovery & 

Waste Mgmt Div., County of 

Santa Barbara - Foxen Canyon, 

County of Santa Barbara - Foxen 

Canyon

03706 03706 104269 Diesel Fired IC Engine 

(Gen 4) 78

SBC Resource Recovery & 

Waste Mgmt Div., County of 

Santa Barbara - Foxen Canyon, 

County of Santa Barbara - Foxen 

Canyon

03706 03706 106429 Diesel Fired IC Engine 

(Gen 5) 78

Southern California Gas 

Company, So Cal Gas - La 

Goleta, La Goleta

05019 01734 001199 IC Engine: Gas 

Compressor # 2 650

Southern California Gas 

Company, So Cal Gas - La 

Goleta, La Goleta

05019 01734 001200 IC Engine: Gas 

Compressor # 3 650

Southern California Gas 

Company, So Cal Gas - La 

Goleta, La Goleta

05019 01734 001201 IC Engine: Gas 

Compressor # 4 650

Southern California Gas 

Company, So Cal Gas - La 

Goleta, La Goleta

05019 01734 001202 IC Engine: Gas 

Compressor # 5 650

Southern California Gas 

Company, So Cal Gas - La 

Goleta, La Goleta

05019 01734 001203 IC Engine: Gas 

Compressor # 6 660
STAFF REPORT - Regulation II/Rule 333 Page C-5

June 19, 2008

Santa Barbara County APCD

Company Name, Stationary 

Source Description, and 

Facility Description

Stat. 

Source 

No.

Fac.

No.

Device 

No. Device Name Bhp

ICE Will Become 

Subject to the 

Emission Limits 

for the 1st time 

due to the Rule 

Revisionsb

Southern California Gas 

Company, So Cal Gas - La 

Goleta, La Goleta

05019 01734 001204 IC Engine: Gas 

Compressor # 7 660

Southern California Gas 

Company, So Cal Gas - La 

Goleta, La Goleta

05019 01734 001205 IC Engine: Gas 

Compressor # 8 660

Southern California Gas 

Company, So Cal Gas - La 

Goleta, La Goleta

05019 01734 001206 IC Engine: Gas 

Compressor # 9 1100

Southern California Gas 

Company, So Cal Gas - La 

Goleta, La Goleta

05019 01734 005666 IC Engine: Electrical 

Generator #1A 170

Southern California Gas 

Company, So Cal Gas - La 

Goleta, La Goleta

05019 01734 005667 IC Engine: Electrical 

Generator #2A 170

Southern California Gas 

Company, So Cal Gas - La 

Goleta, La Goleta

05019 01734 005668 IC Engine: Electrical 

Generator #3A 170

Southern California Gas 

Company, So Cal Gas - La 

Goleta, La Goleta

05019 01734 005669 IC Engine: Electrical 

Generator #20A 144

The Point Arguello Companies, 

The Point Arguello Project, 

Platform Harvest

01325 08013 005000 IC Engine: Crane 

(800A) 503

The Point Arguello Companies, 

The Point Arguello Project, 

Platform Harvest

01325 08013 005001 IC Engine: Crane 

(800B) 503

The Point Arguello Companies, 

The Point Arguello Project, 

Platform Harvest

01325 08013 005002 IC Engine: Crane 

(CR801) 270

The Point Arguello Companies, 

The Point Arguello Project, 

Platform Hermosa

01325 08014 005029 IC Engine: West 

Crane 475

The Point Arguello Companies, 

The Point Arguello Project, 

Platform Hermosa

01325 08014 005030 IC Engine: East Crane 475

The Point Arguello Companies, 

The Point Arguello Project, 

Platform Hidalgo

01325 08015 005058 IC Engine: West 

Crane 475

The Point Arguello Companies, 

The Point Arguello Project, 

Platform Hidalgo

01325 08015 005059 IC Engine: East Crane 475

United States Air Force, 

Vandenberg Air Force Base, 

Vandenberg AFB 30 CES/CEV

01195 00201 006182

IC Engine: Electrical 

Generator (Building 

7425)

115

Venoco, Inc., Venoco -

Carpinteria, Carpinteria Gas Plant 00027 00027 000201 Gas compressor (IR #1) 440
STAFF REPORT - Regulation II/Rule 333 Page C-6

June 19, 2008

Santa Barbara County APCD

Company Name, Stationary 

Source Description, and 

Facility Description

Stat. 

Source 

No.

Fac.

No.

Device 

No. Device Name Bhp

ICE Will Become 

Subject to the 

Emission Limits 

for the 1st time 

due to the Rule 

Revisionsb

Venoco, Inc., Venoco -

Carpinteria, Carpinteria Gas Plant 00027 00027 000202

IC Engine: 

Compressor: SACS 

Cooper (CA-83)

1800

Venoco, Inc., Venoco -

Carpinteria, Carpinteria Gas Plant 00027 00027 000203 Gas compressor (IR #3) 440

Venoco, Inc., Venoco -

Carpinteria, Carpinteria Gas Plant 00027 00027 000204 Gas compressor (IR #4) 300

Venoco, Inc., Venoco -

Carpinteria, Carpinteria Gas Plant 00027 00027 000205 Gas compressor (IR #5) 440

Venoco, Inc., Venoco -

Carpinteria, Carpinteria Gas Plant 00027 00027 000206 Gas compressor (IR #6) 440

Venoco, Inc., Venoco -

Carpinteria, Carpinteria Gas Plant 00027 00027 008166 IC Engine: Dieselfired 180

Venoco, Inc., Venoco -

Carpinteria, Carpinteria Gas Plant 00027 00027 100222

IC Engine: 

Compressor (G-1) 

(Was DID 009138)

220

Venoco, Inc., Venoco - Ellwood, 

Platform Holly 01063 03105 002336 IC Engine: Pedestal Crane 92

Venoco, Inc., Venoco - Ellwood, 

Platform Holly 01063 03105 009130 IC Engine: Drilling Rig Generator #1 803 X

Venoco, Inc., Venoco - Ellwood, 

Platform Holly 01063 03105 009131 IC Engine: Drilling Rig Generator #2 803 X

Venoco, Inc., Venoco - Ellwood, 

Platform Holly 01063 03105 009132 IC Engine: Drilling Rig Generator #3 1053 X

Venoco, Inc., Venoco - Ellwood 

Marine Terminal, Jovalan Barge 01085 03203 002437 IC Engine: VRU 245

Venoco, Inc., Venoco - Ellwood 

Marine Terminal 01085 03203 002438 IC Engine: Generator 89
STAFF REPORT - Regulation II/Rule 333 Page D-1

June 19, 2008

[Annotated draft of June 19, 2008]

Santa Barbara County APCD Rule 102 102 - 1 May 20, 1999[Date of revised rule adoption]

Appendix D

Santa Barbara County 

Annotated Proposed Amended Rule 102, Definitions

RULE 102. DEFINITIONS. (Adopted 10/18/1971, revised 1/12/1976, readopted 10/23/1978, revised 

7/11/1989, 7/10/1990, 7/30/1991, 7/18/1996, 4/17/1997, 1/21/1999, 5/20/1999, 6/19/2003, and 

1/20/2005, and [date of revised rule adoption])

These definitions apply to the entire rulebook. Definitions specific to a given rule are defined in that rule or in the 

first rule of the relevant regulation. Except as otherwise specifically provided in these Rules where the context 

otherwise indicates, words used in these Rules are used in exactly the same sense as the same words are used in 

Division 26 of the Health and Safety Code.

[. . .]

“Alternative Diesel Fuel” means any fuel used in a compression ignition engine that is not commonly or 

commercially known, sold, or represented by the supplier as diesel fuel No. 1-D or No. 2-D, pursuant to the 

specifications in ASTM D 975, “Standard Specification for Diesel Fuel Oils,” ASTM International, or an 

alternative fuel, and does not require engine or fuel system modifications for the engine to operate, although 

minor modifications (e.g., recalibration of the engine fuel control) may enhance performance. Examples of 

alternative diesel fuels include, but are not limited to, biodiesel; Fischer-Tropsch fuels; emulsions of water in 

diesel fuel; and fuels with a fuel additive, unless: 

1. the additive is supplied to the engine fuel by an on-board dosing mechanism, or

2. the additive is directly mixed into the base fuel inside the fuel tank of the engine, or

3. the additive and base fuel are not mixed until engine fueling commences, and no more additive 

plus base fuel combination is mixed than required for a single fueling of a single engine.

[Note 1: This definition is similar to the definition in the Airborne Toxic Control 

Measure for Stationary Compression Ignition Engines. It is needed because the 

term is used in the definition of “dual-fuel engine.”]

[. . .]

“ASTM” means American Society for Testing and Materials. In 2001, the American Society for Testing and 

Materials officially changed its name to “ASTM International.”

[Note 2: The “ASTM” term appears in several rules. Thus, consistent with the 

APCD policy, the definition of the “ASTM” acronym is being added to Rule 102. 

Also, the note after the definition recognizes the official name change to add clarity 

to the references of the “ASTM International” standards.] 

[. . .]

“Compression Ignition Engine” means a reciprocating, internal combustion engine that is not a spark ignition 

engine.

[Note 3: This is modeled on the “compression-ignition” definition in 40 CFR, Part 

89, Subpart A, Section 89.2. Defining the term in Rule 102 is necessary because it is 

used in Rule 202, Rule 333, and Rule 1201.]

[. . .]
STAFF REPORT - Regulation II/Rule 333 Page D-2

June 19, 2008

[Annotated draft of June 19, 2008]

Santa Barbara County APCD Rule 102 102 - 2 May 20, 1999[Date of revised rule adoption]

“Derated” means any physical change to an emission unit to physically limit and restrict the equipment‟s 

power rating from the power rating specified by the manufacturer on the date of initial manufacture of the 

equipment.

[Note 4: The definition is similar to the San Joaquin Valley APCD definition: “Derated Engine: An internal combustion engine which has been physically limited 

and restricted by permit conditions to an operational level of 50 horsepower or 

less.” The Santa Barbara County APCD made it more general to apply to other 

items (e.g., boilers) in Rule 202. It is necessary to define derated in Rule 102 

because Rule 202 refers to Rule 102 in its definition section.]

“Diesel Engine” means a compression ignited four stroke engine that is operated with an exhaust stream oxygen 

concentration of 4 percent by volume, or greater type of internal combustion engine that uses low-volatility 

petroleum fuel and fuel injectors and initiates combustion using compression ignition (as opposed to spark 

ignition that is used with gasoline engines).

[Note 5: The APCD relocated the definition of rated brake horsepower from Rule 

333 and revised the definition. The revised definition is from the CARB “Glossary 

of Air Pollution Terms” on the CARB Web Site: 

http://www.arb.ca.gov/html/gloss.htm. The APCD is adding the term for clarity.]

[. . .]

“Dual-Fuel Engine” means any compression ignition engine that is engineered and designed to operate on a 

combination of alternative fuels, such as compressed natural gas (CNG) or liquefied petroleum gas (LPG) and 

diesel fuel or an alternative diesel fuel. These engines have two separate fuel systems, which inject both fuels 

simultaneously into the engine combustion chamber.

[Note 6: This definition is the same as the definition in the Airborne Toxic Control 

Measure for Stationary Compression Ignition Engines. It is necessary to include 

the definition in Rule 102 to clarify applicable provisions in Rule 202 and Rule 333.]

[. . .]

“Fuel” means any substance that is burned, combusted, or incinerated in an engine, boiler, heater, burner, steam 

generator, process heater, flare, thermal oxidizer, or any other combustion unit, and which includes, but is not 

limited to, gasoline, natural gas, field gas, produced gas, waste gas, methane, digester gas, landfill gas, 

contaminated soil/water cleanup gaseous effluent, ethane, propane, butane, liquefied petroleum gas (LPG), jet 

propellants, diesel fuels, and distillate fuels.

[Note 7: The APCD is adding this definition for clarity. The definition is similar to 

the one found in the Determination of RACT and BARCT for Stationary SparkIgnited Internal Combustion Engines.]
STAFF REPORT - Regulation II/Rule 333 Page D-3

June 19, 2008

[Annotated draft of June 19, 2008]

Santa Barbara County APCD Rule 102 102 - 3 May 20, 1999[Date of revised rule adoption]

“Fuel Additive” means any substance designed to be added to fuel or fuel systems or other engine-related engine 

systems such that it is present in-cylinder during combustion and has any of the following effects: decreased 

emissions, improved fuel economy, increased performance of the engine; or assists diesel emission control 

strategies in decreasing emissions, or improving fuel economy or increasing performance of the engine.

[Note 8: This definition is the same as the one found in the Airborne Toxic Control 

Measure for Stationary Compression Ignition Engines. It is necessary to clarify the 

definition of alternative diesel fuel.]

[. . .]

“Higher Heating Value” means the total heat liberated per mass of fuel burned (British thermal unit per

pound), when fuel and dry air at standard conditions undergo complete combustion and all resulting products 

are brought to their standard states at standard conditions. “Gross heating value” shall have the same meaning 

as “higher heating value.”

[Note 9: The term higher heating value is being added to Rule 102 because the term 

is used in more than one prohibitory rule. The reference to the gross heating value 

having the same meaning as higher heating value is added for clarity. The term 

“gross heating value” is found in the Rule 210, Schedule A.3.]

“Internal Combustion Engine” means an engine in which both the heat energy and the ensuing mechanical 

energy are produced inside the engine. Internal combustion engines include gas turbines, spark ignition, and 

compression ignition engines.

[Note 10: This definition is from the CARB “Glossary of Air Pollution Terms” on 

the CARB Web Site. The APCD is adding the term for clarity.]

[. . .]

“Portable iInternal cCombustion eEngine” means any internal combustion engine that is portable, meaning 

it is carried or moved from one location to another in the normal course of business. Indicia of portability 

shall include, but are not limited to, wheels, skids, carrying handles, or a dolly, trailer, vessel, or platform, or 

mounting. “Portable internal combustion engine” does not include an engine used to propel nonroad 

equipment or a motor vehicle of any kind, including, but not limited to, a heavy duty vehicle. The engine is 

not portable if: 

1. the engine or its replacement is attached to a foundation, or if not so attached, will reside at the 

same location for more than 12 consecutive months. The period during which the engine is 

maintained at a storage facility shall be excluded from the residency time determination. Any 

engine, such as a back-up or stand-by engine, that replace engine(s) at a location, and is intended 

to perform the same or similar function as the engine(s) being replaced, will be included in 

calculating the consecutive time period. In that case, the cumulative time of all engine(s), including 

the time between the removal of the original engine(s) and installation of the replacement 

engine(s), will be counted toward the consecutive time period; or 

2. the engine remains or will reside at a location for less than 12 consecutive months if the engine is 

located at a seasonal source and operates during the full annual operating period of the seasonal 

source, where a seasonal source is a stationary source that remains in a single location on a 

permanent basis (at least two years) and that operates at that single location at least three months 

each year; or 
STAFF REPORT - Regulation II/Rule 333 Page D-4

June 19, 2008

[Annotated draft of June 19, 2008]

Santa Barbara County APCD Rule 102 102 - 4 May 20, 1999[Date of revised rule adoption]

3. the engine is moved from one location to another in an attempt to circumvent the portable 

residence time requirements. 

[Note 11: The APCD used the ARB definition of portable in the Statewide Portable 

Equipment Registration Program (PERP) to model the revised definition of 

portable internal combustion engine.]

[. . .]

“Rated brake horsepower” means the maximumcontinuous brake horsepower rating at maximum revolutions per 

minute (RPM) specified for the engine by the manufacturer. Alternately, the rated brake horsepower of an engine 

shall be the maximum allowable and enforceable rating specified by the District, stated in the Permit to Operate 

(PTO), and accepted by the engine operator or listed on the original nameplate of the unit, unless otherwise 

physically limited and specified by a condition on the engine's Permit to Operate.

[Note 12: The APCD relocated the definition of rated brake horsepower from Rule 

333 and revised the definition. EPA identified the rated brake horsepower definition 

as a rule deficiency in a November 1994 Technical Support Document. Their 

concern indicates, in part, “EPA believes the definition should specify rating as 

output determined by the manufacturer and listed on the nameplate, regardless of 

any derating.” Although the revised definition may not completely address the 

EPA concern, it is similar to the San Joaquin Valley Unified APCD (SJV) Rule 4701 

and Rule 4702 definitions. EPA approved those SJV rules into the SIP on May 18, 

2004 (69 FR 28061). Thus, we do not anticipate EPA identifying the engine 

derating component of the definition to be a future rule deficiency.]

[Note 13: It is necessary to have the definition in Rule 102 because the term is used 

in Rule 202 and Rule 333.]

[. . .]

“Spark Ignition Engine” means a gasoline-fueled engine or other engine with a spark plug (or other sparking 

device) and with operating characteristics significantly similar to the theoretical Otto combustion cycle. Spark

ignition engines usually use a throttle to regulate intake air flow to control power during normal operation.

[Note 14: This is similar to the definition of “spark-ignition” in 40CFR 89.2. It is 

necessary to have the definition in Rule 102 because the term is used in Rule 202 

and Rule 333.]

[. . .]

“Specialty Equipment” means portable engines used to power equipment located in the Outer Continental 

Shelf or State Territorial Waters that satisfy all of the following conditions:

1. The portable engine is ineligible for registration in the State Portable Equipment Registration 

Program; and

2. A similar portable engine or equipment unit capable of performing the specialty work is not 

registered in the State Portable Equipment Registration Program or, if registered is not available 

for use; and
STAFF REPORT - Regulation II/Rule 333 Page D-5

June 19, 2008

[Annotated draft of June 19, 2008]

Santa Barbara County APCD Rule 102 102 - 5 May 20, 1999[Date of revised rule adoption]

3. The portable engine/equipment unit performs a unique function or activity outside the normal 

scope of drilling or construction activities; and

4. The equipment will be used for less than 500 hours per stationary source in any calendar year and 

emit not more than 10 tons per stationary source of oxides of nitrogen, oxides of sulfur, reactive 

organic compounds, or particulate matter in any calendar year; and

5. Use of the equipment is not recurrent from year to year.

“Specialty Equipment Emergency Use” means that conditions giving rise to the use of the specialty 

equipment were due to 1) conditions beyond the reasonable control of the stationary source, including but not 

limited to the breakdown of essential drilling or construction equipment, and 2) the use of the specialty 

equipment is necessary to complete essential short-term projects.

[Note 15: The above two definitions are needed because of the newly-proposed 

“specialty equipment” exemption in Rule 202, Section F.5. The APCD is adding 

that exemption in response to an industry request. The definitions were modified 

after the February 13, 2008 workshop to address issues raised by the regulated 

community. These revisions included extending the Specialty Equipment definition 

to State Territorial Waters and adding or construction text to the definitions.]

[. . .]
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STAFF REPORT - Regulation II/Rule 333 Page E-1

June 19, 2008

[draft of June 19, 2008]

Santa Barbara County APCD Rule 201 201 - 1 April 17, 1997[Date of revised rule adoption]

Appendix E

Santa Barbara County 

Annotated Proposed Amended Rule 201, Permits Required

RULE 201. PERMITS REQUIRED. (Adopted 10/18/1971, revised 5/1/1972, readopted 10/23/1978, revised 

7/2/1979, and 4/17/1997, and [date of revised rule adoption])

A. Applicability

This rule applies to any person who builds, erects, alters, replaces, operates or uses any article, machine, 

equipment, or other contrivance which may cause the issuance of air contaminants. 

B. Exemptions

Exemptions to this rule appear in Rule 202 (Exemptions to Rule 201). 

C. Definitions

See Rule 102 for definitions not limited to this rule. For the purposes of this rule, the following definitions 

shall apply: 

"Erect" means the setting up, installing, or assembling of equipment that can be moved from one location to 

another and that must be stationary in order to operate. 

D. Requirement - Authority to Construct

1. Any person building, erecting, altering, or replacing, or using any article, machine, 

equipment or other contrivance, the use of which may cause the issuance of air contaminants or the 

use of which may eliminate or reduce or control the issuance of air contaminants, shall first obtain an 

Authority to Construct for such construction or use from the Control Officer. An Authority to 

Construct issued to a source shall remain in effect until the Permit to Operate the equipment for which 

the application was filed is granted or denied or the application expires.

[Note 1: Adding the text “using” and “or use” is consistent with the Health and 

Safety Code Section 42300(a) provisions. Section D.1 is becoming Section D.]

2. Notwithstanding any exemption in these rules and regulations, equipment used for the dredging of 

waterways, except during emergencies declared by public officials in accordance with state law, or 

equipment used in pile driving adjacent to or in waterways, or pipe-laying and derrick barges, shall 

obtain an Authority to Construct and a Permit to Operate when the potential to emit of such 

equipment per stationary source is equal to or greater than 25 tons per year of any affected pollutant 

during any consecutive 12 month period. The Control Officer shall not require Best Available 

Control Technology for such sources if federal law preempts this requirement.

[. . .]

[Note 2: The APCD is moving the Section D.2 provision into Rule 202, Section F.7 to 

group the exemptions together. The proposed revised text found in Rule 202.F.7 

provides clarification on when permits are required and helps address some of the 

regulated community’s concerns with the removal of the construction exemption

(Rule 202.F.3). The proposed new Section 202.F.8 also provides NSR options for 

marine vessel engines associated with stationary source activities.]
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STAFF REPORT - Regulation II/Rule 333 Page F-1

June 19, 2008

[Annotated draft of June 19, 2008]

Santa Barbara County APCD Rule 202 202 - 1 April 17, 1997[Date of revised rule adoption]

Appendix F

Santa Barbara County 

Annotated Proposed Amended Rule 202, Exemptions to Rule 201

RULE 202. EXEMPTIONS TO RULE 201. (Adopted 10/18/1971, revised 5/1/1972 and 6/27/1977, 

readopted 10/23/1978, revised 12/7/1987, 1/11/1988, 1/17/1989, 7/10/1990, 7/30/1991, 

11/05/1991, 3/10/1992, 5/10/1994, 6/28/1994, and 4/17/1997, and [date of revised rule 

adoption])

A. Applicability

An Authority to Construct or Permit to Operate shall not be required for equipment, operations, and 

activities described herein.

B. Exceptions

Notwithstanding any exemption created by this Rulerule, any:

1. eEquipment, activity or operations proposed by an applicant for use as an Emission Reduction 

Credit is not exempt. 

2. Emission unit that functions for distributed electrical generation and is not certified under the 

regulations of the Air Resources Board is not exempt.

[Note 1: The new provision on distributed electric generation equipment is 

needed for consistency with the California Administrative Code, Title 17, 

Section 94201(d) provisions on the applicability of the California distributed 

generation certification program.]

[. . .]

D. General Provisions

[. . .]

5. Temporary Equipment

A permit shall not be required for temporary equipment where the projected actual aggregate 

emissions of all affected pollutants do not exceed 1 ton (except carbon monoxide, which shall not 

exceed 5 tons) and the use of each individual piece of equipment does not exceed one 60 day 

period in any consecutive 12 month period. Such equipment shall also meet one of the following 

requirements:

a. the temporary equipment is not part of an existing operating process of a stationary 

source; or

b. the temporary equipment replaces equipment that has qualified for a breakdown pursuant 

to Rule 505.
STAFF REPORT - Regulation II/Rule 333 Page F-2

June 19, 2008

[Annotated draft of June 19, 2008]

Santa Barbara County APCD Rule 202 202 - 2 April 17, 1997[Date of revised rule adoption]

To qualify for this exemption, the owner or operator shall submit a written request to the Control 

Officer, who shall make a determination in writing approving or denying the request. This request 

shall identify the temporary equipment, its location, any equipment being replaced, and shall 

include the emission calculations and assumptions that demonstrate that the equipment meets the 

exemption criteria. The temporary project may commence as soon as the written request has been 

made, however, project commencement with equipment that is later found ineligible for the 

exemption shall constitute a violation of the District‟s Rules and Regulations. This exemption 

shall not apply to equipment used for the specific purpose to control emissions of Hazardous Air 

Pollutants Toxic Air Contaminants. The owner or operator shall pay any applicable fee pursuant 

to Rule 210.

[Note 2: The new text on the APCO making a written determination for the 

exemption is needed for clarification and uniformity within Rule 202. Owners 

and operators seeking an exemption per Rule 202, Sections D.5, D.7, F.5, F.7, 

K.6, and P.14 shall file an APCD-38 Form, Request for Written Determination 

of Permit Exemption, along with the fee.] 

[Note 3: The terminology for the specific purpose is added to make the 

exemption applicable to systems that have small amounts of TACs while 

requiring control systems for vapor streams that are composed of TACs to be 

subject to permitting. Without this change, the use of a vapor recovery system 

on a temporary tank would require a permit because small amounts of TACs 

would be directed to the vapor recovery system.]

[Note 4: The change from Hazardous Air Pollutants (HAPs) to Toxic Air 

Contaminants (TACs) is necessary to cover certain air pollutants (e.g., 

ammonia, copper compounds, diesel exhaust) that are listed as a TAC but not 

listed as a Hazardous Air Pollutant.]

[. . .]

7. Stationary Source Permit Exemption

A permit shall not be required for any new, modified or existing stationary source if the 

uncontrolled actual emissions of each individual affected pollutant from the entire stationary 

source are below 1.00 ton per calendar year, unless:

[. . .]

Each owner or operator who desires seeking this exemption shall submit an a written request to the 

Control Officer, who shall make a determination in writing approving or denying the 

requestexemption request form and obtain written concurrence from the District. A fee shall be 

assessed as specified in The owner or operator shall pay any applicable fee pursuant to Rule 210

(Schedule F).

[Note 5: The reasons for these changes are discussed in Note 2.]

[. . .]

11. Where an exemption is described in this Rule rule for a general category of equipment, the 

exemption shall not apply to any component which otherwise would require a permit under the 

provisions of these Rules and Regulations.

See Note 

2.

See Notes 

3 and 4.
STAFF REPORT - Regulation II/Rule 333 Page F-3

June 19, 2008

[Annotated draft of June 19, 2008]

Santa Barbara County APCD Rule 202 202 - 3 April 17, 1997[Date of revised rule adoption]

[. . .]

15. For the purposes of the exemptions set forth in F.1.e; F.1.f; F.1.g; and G.1, the ratings of all 

engines or combustion equipment used in the same process shall be accumulated to determine 

whether these exemptions apply.

[Note 6: This provision clarifies that several emission units are treated as one 

emission unit where simultaneous operation of two or more emission units in 

the same process could occur to meet operation and/or system demands. This 

is consistent with past practice. A determination that equipment is used in the 

same process is based on the engineering design. For example, analysis will 

involve looking at the equipment’s or system’s maximum energy needs or 

demands under a worst-case scenario.

16. Notwithstanding any exemption in these rules and regulations, if the combined emissions from all 

construction equipment used to construct a stationary source which requires an Authority to 

Construct have a projected actual in excess of 25 tons of any pollutant, except carbon monoxide, in 

a 12 month period, the owner of the stationary source shall provide offsets as required under the 

provisions of Rule 804 and shall demonstrate that no ambient air quality standard would be 

violated.

[Note 7a: The proposed new Rule 202, Section D.16 text is essentially the same text 

found in the current Rule 202.F.3. Although the APCD is proposing to delete the 

Rule 202.F.3 exemption for engines used in construction, it is necessary to maintain 

the portion of the 202.F.3 text on offset requirements. The intent is to not remove 

large stationary source construction mitigation.]

17. No additional permit shall be required at a stationary source in the District for equipment permitted 

by the District for various location uses provided the following conditions are met:

a. The owner or operator of the equipment has a valid Permit to Operate issued by the 

District that specifically denotes the equipment as being usable at various locations within 

the District and that the terms and conditions of the Permit to Operate are fully complied 

with.

b. The equipment is not used to replace equipment which is part of an existing process at the 

stationary source.

c. The equipment is used for repair and maintenance related purposes only.

d. The stationary source reports all uses (including the start and end dates) and associated 

emissions for each use under this exemption to the APCD in their next annual report (or 

semi-annual report for Part 70 sources).

[Note 7b: The APCD is adding this provision in response to comments from 

industry.]

[. . .]
STAFF REPORT - Regulation II/Rule 333 Page F-4

June 19, 2008

[Annotated draft of June 19, 2008]

Santa Barbara County APCD Rule 202 202 - 4 April 17, 1997[Date of revised rule adoption]

F. Internal Combustion Engines

1. A permit shall not be required for internal combustion engines if any of the following conditions is 

satisfied:

a. Engines used in aircraft and in locomotives;

b. Engines used to propel marine vessels, except vessels associated with a stationary source 

which shall be regulated as specified under the provisions of Regulation VIII. 

c. Engines used to propel vehicles, as defined in Section 670 of the California Vehicle 

Code, but not including any engine mounted on such vehicles that would otherwise 

require a permit under the provisions of these Rules and Regulations.

d. Spark ignition piston-type internal combustion engines used exclusively for emergency 

electrical power generation or emergency pumping of water for flood control or 

firefighting if the engine operates no more than 200 hours per calendar year, and where a 

record is maintained and is available to the District upon request; the record shall list the 

identification number of the equipment, the number of operating hours on each day the 

engine is operated and the cumulative total hours.

 

e. Compression ignition engines with a rated brake horsepower of less than 50 or less. No 

compression ignition engine otherwise subject to permit shall be exempt because it has 

been derated.

[Note 8: The addition of the word “rated” before brake horsepower is needed for 

consistency with the new rated brake horsepower definition in Rule 102. The cutoff 

is being revised from 50 brake horsepower (bhp) or less to less than 50 bhp. This is 

necessary for consistency with the California Airborne Toxic Control Measure for 

Diesel Particulate Matter from Portable Engines Rated at 50 Horsepower and 

Greater (California Code of Regulations, Title 17, Sections 93116 et seq.).]

[Note 9: The new provision on permitting derated equipment is necessary to ensure 

that the derating method is enforceable.]

f. Spark ignition piston-type internal combustion engines with a manufacturer's maximum 

rating of 100 rated brake horsepower of less than 50. or less or gas turbine engines with 

a maximum heat input rate of 3 million British thermal units per hour or less at standard 

conditions, except if the total horsepower of individual spark ignition piston-type internal 

combustion engines less than 100 brake horsepower but greater than 20 brake horsepower 

at a stationary source, as defined in Rule 102, exceeds 500 bhp in which case the 

individual engines are not exempt. Notwithstanding the previous sentence, none of the 

individual engines in the range of less than 50 but greater than 20 rated brake horsepower 

are exempt if such engines at a stationary source have a total rated brake horsepower 

rating of 400 or greater.

No spark ignition piston-type internal combustion engine otherwise subject to permit shall 

be exempt because it has been derated. Spark ignition piston-type Internal internal 

combustion engines exempt under other provisions of Section F and permitted spark 

ignition piston-type internal combustion engines do shall not count toward the 500 400

bhp rated brake horsepower aggregate limit.

See Notes 10 

and 11.

See Note 12.

See Note 

13.

See Note 

14.
STAFF REPORT - Regulation II/Rule 333 Page F-5

June 19, 2008

[Annotated draft of June 19, 2008]

Santa Barbara County APCD Rule 202 202 - 5 April 17, 1997[Date of revised rule adoption]

[Note 10: The addition of the word “rated” before brake horsepower is needed for 

consistency with the new rated brake horsepower definition in Rule 102.]

[Note 11: Less than 50 bhp Threshold for the Single-Engine Exemption for Spark 

Ignition Piston-Type Engines: The exemption, on a single-engine basis, is being 

changed from the permitting threshold of greater than 100 brake horsepower to 50 

brake horsepower and greater. Lowering the single-engine exemption threshold 

from 100 to less than 50 brake horsepower is consistent with an EPA-identified 

deficiency, requirements in adjoining APCDs, and the ARB Determination of 

Reasonably Available Control Technology and Best Available Retrofit Control 

Technology for Stationary Spark-Ignited Internal Combustion (ARB 

RACT/BARCT Determination).]

[Note 12: The exemption on gas turbine engines is being moved to Section F.1.g.]

[Note 13: Exemption for Sources with Multiple Spark Ignition Piston-Type 

Engines: For situations where there are several spark ignition engines at the same 

stationary source, the proposed revised provision will:

1. Change the less than 100 but greater than 20 brake horsepower range for 

assessing the total rated brake horsepower sum to less than 50 but greater than 

20 brake horsepower.

2. Change the amount for the permitting threshold from 500 brake horsepower to 

400 brake horsepower. 

 

Revising the range to be greater than 20 to less than 50 brake horsepower is 

consistent with permitting engines rated 50 brake horsepower and greater. The 

APCD is setting the “gatekeeper” figure at 400 brake horsepower based on the 

distribution of engines in the 2005 inventory.]

[Note 14: The new provision on permitting derated equipment is necessary to 

ensure that the derating method is enforceable. Indicating permitted engines are 

not counted towards the 400 brake horsepower aggregate limit is appropriate 

because these engines already require permitting.]

g. Gas turbine engines with a maximum heat input rating of 3 million British thermal units 

per hour or less at standard conditions. No gas turbine engine otherwise subject to permit 

shall be exempt because it has been derated. For the purposes of this section, power 

generating microturbines fired on natural gas which meets General Order 58-A of the 

Public Utility Commission that have been certified by the Air Resources Board to meet 

the applicable distributed generation standards certified by a current Air Resources Board 

Executive Order are not subject to the provisions of Section D.15 if the potential annual 

emissions of each affected pollutant does not exceed 1 ton (except carbon monoxide, 

which shall not exceed 5 tons).

[Note 15: This sentence is currently within Rule 202.F.1.f. For clarity, it is being 

moved to a separate section.]

See Note 

16.

See Note 15.

See Note 

17.
STAFF REPORT - Regulation II/Rule 333 Page F-6

June 19, 2008

[Annotated draft of June 19, 2008]

Santa Barbara County APCD Rule 202 202 - 6 April 17, 1997[Date of revised rule adoption]

[Note 16: The new provision on permitting derated equipment is necessary to 

ensure that the derating method is enforceable.]

[Note 17: This text allows for limited “grouping/multi-packing” of microturbine 

engines under certain conditions. The greater than 1 ton per year (except CO, 

which is 5 tons per year) pollutant threshold stems from previously EPA-approved 

levels for APCD exemptions.]

2. A permit shall not be required for portable engines registered in the Statewide Registration 

Program, pursuant to California Code of Regulations, title 13, section 2451 et seq. and Health and 

Safety Code Section 41753 et seq. Notwithstanding this provision, the requirements of Section F.3 

D.16 shall apply to such portable engines and the requirements of Section F.6 shall apply to such 

portable engines used in the outer continental shelf. All operators using this permit exemption 

shall comply with the State Portable Equipment Registration Program and Air Resources Boardissued registration.

[Note 18: The replacement of the reference to Section F.3 with Section D.16 is 

needed because the Section F.3 provision on construction equipment offset 

requirements is being moved to Section D.16.]

[Note 19: The deletion of the Section F.6 text is necessary because the exemption 

for well drilling in state territorial waters (STW) and the outer continental shelf 

(OCS) is being deleted.]

[Note 20: The APCD is adding this provision to ensure that all operators (i.e., those 

located onshore, in STW, and the OCS) of engines registered in the State Portable 

Equipment Registration Program (PERP) availing themselves to the exemption 

comply with the requirements of the PERP and the ARB-issued registration for 

their engine.]

3. A permit shall not be required for engines used in construction activities. However, if the 

combined emissions from all construction equipment used to construct a stationary source which 

requires an Authority to Construct have the potential to exceed 25 tons of any pollutant, except 

carbon monoxide, in a 12 month period, the owner of the stationary source shall provide offsets as 

required under the provisions of Rule 804 and shall demonstrate that no ambient air quality 

standard would be violated.

[Note 21: Rule 202 will no longer provide an exemption for construction engines. 

The owners and operators of such engines should be registering them in the 

Statewide Portable Equipment Registration Program. The construction engine 

offset provision is being moved to the general provisions of Rule 202 (new Section 

D.16).]

4. A permit shall not be required for engines used for aircraft shows or to power amusement rides at 

seasonal or special occasion shows, fairs, expositions, circuses or carnival events, provided that the 

duration of such event is less than 18 days in any calendar year.

54. A permit shall not be required for engines with a rated brake horsepower of less than 50 bhp used:

a. for military tactical support operations including maintenance and training for such 

operations;

See Notes 

18 and 19.

See Note 

20.
STAFF REPORT - Regulation II/Rule 333 Page F-7

June 19, 2008

[Annotated draft of June 19, 2008]

Santa Barbara County APCD Rule 202 202 - 7 April 17, 1997[Date of revised rule adoption]

b. to power temperature and humidity control systems on cargo trailers used to transport 

satellites and space launch equipment;

c. exclusively for space launch facility support and which power hoists, jacks, pulleys, and 

other cargo handling equipment permanently affixed to motor vehicles or trailers pulled 

by motor vehicles. 

[Note 22: This change is needed to eliminate the bhp acronym.]

65. A permit shall not be required for drilling specialty equipment. used in state waters or in the outer 

continental shelf provided the emissions from such equipment are less than 25 tons per stationary 

source of any affected pollutant during any consecutive 12 month period. To qualify for this 

exemption, the owner or operator of the stationary source shall submit a written request to the 

Control Officer, who shall make a determination in writing approving or denying the request. The 

owner or operator shall pay any applicable fee pursuant to Rule 210. For specialty equipment 

emergency use, operations may commence as soon as the written request has been made; however, 

operation of equipment which is later found ineligible for the exemption shall constitute a violation 

of the District‟s Rules and Regulations. 

[Note 23: Rule 202 will no longer provide a general exemption for offshore drilling 

equipment. The owners of portable engines should be registering them in the 

Statewide Portable Equipment Registration Program. Owners of existing 

stationary well drilling engines located on the platforms have 90 days to submit a 

PTO application per Rule 202.E.]

[Note 24: Industry requested that Rule 202 include an exemption for specialty 

equipment due to the loss of the drilling exemption. Additional provisions have 

been added for “specialty equipment” and “specialty equipment emergency use.”] 

76. An internal combustion engine which powers an item of equipment identified as exempt in any 

other part of this Rule rule is not exempt unless the engine qualifies for an exemption pursuant to 

this rule.

7. A permit shall not be required for Notwithstanding any exemption in these rules and regulations, 

equipment used for the dredging of waterways, except during emergencies declared by public officials 

in accordance with state law, or equipment, including associated marine vessels, used in for pile 

driving adjacent to or in waterways, or cable and pipe-laying vessels/barges or and derrick barges, 

shall obtain an Authority to Construct and a Permit to Operate when if the potential to emit of such 

equipment per stationary source is less equal to or greater than 25 tons per year of any affected 

pollutant during any consecutive 12 month period. The Control Officer shall not require Best 

Available Control Technology for such sources if federal law preempts this requirement. To qualify 

for this exemption, the owner or operator of the stationary source shall submit a written request for 

exemption to the Control Officer, who shall make a determination in writing approving or denying the 

request. The request shall identify the equipment, its location, and shall include the emission 

calculations and assumptions that demonstrate that the equipment meets the exemption criteria. The 

owner or operator shall pay any applicable fee pursuant to Rule 210. Alternatively, an owner or 

operator of the stationary source may qualify for an exemption from the New Source Review 

provisions of Regulation VIII by obtaining an Authority to Construct and Permit to Operate which 

limits the potential to emit of such equipment to less than 25 tons per year of any affected pollutant 

during any consecutive 12 month period. 

[Note 25: The APCD relocated the Rule 201.D.2 provision here at the request of 

industry to include this exemption with other exemptions. The proposed revised 
STAFF REPORT - Regulation II/Rule 333 Page F-8

June 19, 2008

[Annotated draft of June 19, 2008]

Santa Barbara County APCD Rule 202 202 - 8 April 17, 1997[Date of revised rule adoption]

text provides clarification on when permits are required and helps address some of 

the regulated community’s concerns with the removal of the construction 

exemption (Rule 202.F.3). It provides stationary sources with the ability to exempt 

qualifying equipment from the requirement to obtain an ATC under Regulation 

VIII.]

8. For purposes of Regulation VIII, the following shall not be subject to New Source Review: Marine 

vessel engines (propulsion engines, auxiliary engines and permanently affixed support engines) 

associated with construction, maintenance, repair and/or demolition activities at a stationary source 

provided the duration of the activities do not exceed 12 consecutive months and the potential to emit 

of such engines per stationary source is less than 10 tons per stationary source of oxides of nitrogen, 

oxides of sulfur, reactive organic compounds or particulate matter. To qualify for this exemption, the 

owner or operator of the stationary source shall submit a written request for exemption to the Control 

Officer, who shall make a determination in writing approving or denying the request. The request 

shall identify the marine vessels, project activities, duration, and shall include the emission 

calculations and assumptions demonstrating that the engines meet the exemption criteria. The owner 

or operator shall pay any applicable fee pursuant to Rule 210. Alternatively, an owner or operator of 

the stationary source may qualify for an exemption by obtaining an Authority to Construct and Permit 

to Operate which limits the potential to emit of such equipment to less than 10 tons per year. Such 

Authority to Construct/Permit to Operate shall be exempt from Regulation VIII.

[Note 26: With the removal of the construction exemption (202.F.3.), engines used 

to propel marine vessels associated with a stationary source construction project 

will need to be permitted (see 202.F.1.b). The addition of new Rule 202.F.8 will 

help address some of the regulated community’s concerns with the removal of the 

construction exemption.]

G. Combustion Equipment (Other than Internal Combustion Engines)

Notwithstanding the listed exemptions, any collection of articles, machines, equipment or other 

contrivances within each listed equipment category at a stationary source that has aggregate emissions in 

excess of 25 tons per calendar year of any affected pollutant is not exempt.

1. Combustion equipment with a maximum heat input of less than or equal to two (2) million British 

thermal units per hour is exempt from permit requirements if fired exclusively with one of the 

following:

a. Natural or produced gas which meets General Order 58-A of the Public Utility 

Commission,

b. Liquefied petroleum gas, which meets Gas Processors Association Standards,

c. A combination of natural or produced and liquefied petroleum gas, meeting the 

requirements of subdivisions (a) and (b) above.

Combustion equipment with a maximum heat input rate of 1 million British thermal units per hour 

or less is exempt and does not count towards the 25 tons per calendar year stationary source 

exemption threshold listed above in this paragraph, provided the equipment is fired exclusively 

with fuel listed above in a, b, or c listed above in this paragraph. No combustion equipment 

otherwise subject to permit shall be exempt because it has been derated.
STAFF REPORT - Regulation II/Rule 333 Page F-9

June 19, 2008

[Annotated draft of June 19, 2008]

Santa Barbara County APCD Rule 202 202 - 9 April 17, 1997[Date of revised rule adoption]

[Note 27: The text has been revised for consistency and clarity. The last sentence is 

added to ensure that the derating method is enforceable.]

2. Combustion equipment (other than internal combustion engines) which provides heat energy to any 

item of equipment identified as exempt in any other part of this Rulerule, is not exempt unless fired 

exclusively with one of the fuels listed in G.1.a., G.1.b., or G.1.c. the combustion equipment is 

exempt as specified in G.1.

[Note 28: This section is being revised for consistency and clarity.]

[. . .]

I. Coatings Applications Equipment and Operations

The following listed coating applications equipment and operations is exempt from permit requirements. 

Notwithstanding the listed exemptions, any collection of articles, machines, equipment or other 

contrivances within each listed equipment category at a stationary source that has aggregate emissions in 

excess of 10 tons per calendar year of any affected pollutant is not exempt.

[. . .]

5. Polyurethane powder Powder coating operations, provided the powder coating material reactive 

organic compound content is equal to or less than five percent, by weight.

[Note 29: At the request of industry, the APCD is revising this exemption to include 

all powder coating materials with an ROC content not exceeding five percent by 

weight.]

[. . .]

K. Food Processing and Preparation Equipment

The following listed food processing and preparation equipment is exempt from permit requirements. 

Notwithstanding the listed exemptions, any collection of articles, machines, equipment or other 

contrivances within each listed equipment category at a stationary source that has aggregate emissions in 

excess of 10 tons per calendar year of any affected pollutant is not exempt.

[. . .]

7. Fermentation, aging, and bottling process operations conducted at wineries, breweries, distilleries 

and similar facilities, provided the projected actual emissions from such operations for each 

individual affected pollutant from the entire stationary source are below 1.00 ton per calendar year. 

To qualify for this exemption, the owner or operator shall submit a written request to the Control 

Officer, who shall make a determination in writing approving or denying the request. The owner 

or operator shall pay any applicable fee pursuant to Rule 210.

[Note 30: Wineries, breweries, and distilleries have been considered exempt per 

Rule 202.D.7 (the one ton per year exemption). The APCD proposes this separate 

exemption to provide a stand-alone exemption for such activities.]

[. . .]

L. General Utility Equipment and Operations
STAFF REPORT - Regulation II/Rule 333 Page F-10

June 19, 2008

[Annotated draft of June 19, 2008]

Santa Barbara County APCD Rule 202 202 - 10 April 17, 1997[Date of revised rule adoption]

The following listed general utility equipment and operations is exempt from permit requirements. 

Notwithstanding the listed exemptions, any collection of articles, machines, equipment or other 

contrivances within each listed equipment category at a stationary source that has aggregate emissions in 

excess of 10 tons per calendar year of any affected pollutant is not exempt.

[. . .]

15. Notwithstanding G.2 of this rule, portable steam cleaning/pressure washing equipment with 

maximum heat input rating less than 1 million Btu/hr British thermal units per hour fired 

exclusively on diesel fuel. 

16. Notwithstanding G.2 of this rule, portable water heaters used exclusively for underwater diving 

activities with a maximum heat input rating less than 1 million British thermal units per hour fired 

exclusively on diesel fuel.

[Note 31: At the request of industry, the APCD is adding an exemption for water 

heaters that provide underwater divers with heated water to prevent hypothermia.]

[. . .]

P. Miscellaneous Equipment and Operations

The following miscellaneous equipment and operations is exempt from permit requirements. 

Notwithstanding the listed exemptions, any collection of articles, machines, equipment or other 

contrivances within each listed equipment category at a stationary source that has aggregate emissions in 

excess of 10 tons per calendar year of any affected pollutant is not exempt.

[. . .]

14. For purposes of Regulation VIII, the following shall not be subject to New Source Review: 

Marine vessel engines (propulsion engines, auxiliary engines and permanently affixed support 

engines) associated with launch vehicle recovery operations for the Missile Defense Agency‟s 

Airborne Laser program provided the potential to emit is less than 5 tons per year of oxides of 

nitrogen, oxides of sulfur, reactive organic compounds or particulate matter. To qualify for this 

exemption, the owner or operator of the stationary source shall submit a written request for 

exemption to the Control Officer, who shall make a determination in writing approving or denying 

the request. The request shall identify the marine vessels, project activities, duration, and shall 

include the emission calculations and assumptions demonstrating that the engines meet the 

exemption criteria. The owner or operator shall pay any applicable fee pursuant to Rule 210. 

Alternatively, an owner or operator of the stationary source may qualify for an exemption by 

obtaining an Authority to Construct and Permit to Operate which limits the potential to emit of 

such equipment to less than 5 tons per year. Such Authority to Construct/Permit to Operate shall 

be exempt from Regulation VIII.

[Note 32: The APCD is adding this exemption in response to a request from 

Vandenberg Air Force Base.]

[. . .]
STAFF REPORT - Regulation II/Rule 333 Page F-11

June 19, 2008

[Annotated draft of June 19, 2008]

Santa Barbara County APCD Rule 202 202 - 11 April 17, 1997[Date of revised rule adoption]

U. Solvent Application Equipment and Operations

The following solvent application equipment and operations is exempt from permit requirements. 

Notwithstanding the listed exemptions, any collection of articles, machines, equipment or other 

contrivances within each listed equipment category at a stationary source that has aggregate emissions in 

excess of 10 tons per calendar year of any affected pollutant is not exempt.

[. . .]

3. Equipment used in wipe cleaning operations, provided that the solvents used do not exceed 55 

gallons per year per stationary source. 

To qualify for this exemption, the owner or operator shall maintain records of the amount (gallons 

per year) of solvents used at the stationary source for each calendar year. 

These records shall be kept maintained on site for a minimum of at least 3 years and be made 

available to the District on request. Thereafter, the records shall be maintained either on site or 

readily available for expeditious inspection and review for an additional 2 years. Solvents meeting 

the criteria of 2.b. or c. above do not contribute to the 55 gallons per year per stationary source 

limitation.

[Note 33: The per stationary source and at the stationary source text is being added 

for clarity. Specifying that the exemption applies on a stationary source basis is 

consistent with the legislative intent when this provision was added in 1997.]

[Note 34: Changes to the record retention provisions are consistent with the EPA 

policy.]

[. . .]

See Note 

34.

See Note 33.

See Note 

33.
THIS PAGE INTENTIONALLY LEFT BLANK
STAFF REPORT - Regulation II/Rule 333 Page G-1

June 19, 2008

[Annotated draft of June 19, 2008]

Santa Barbara County APCD Rule 333 333 - 1 April 17, 1997[Date of revised rule adoption]

Appendix G

Santa Barbara County 

Annotated Proposed Amended Rule 333, Control of Emissions from 

Reciprocating Internal Combustion Engines

RULE 333. CONTROL OF EMISSIONS FROM RECIPROCATING INTERNAL COMBUSTION 

ENGINES. (Adopted 12/03/1991, revised 12/10/1991, and 4/17/1997, and [date of revised rule 

adoption])

A. Applicability

1. The provisions of this rule shall apply to all any engines with a rated brake horsepower of 50 or 

greater and which are fueled by natural gas, field gas, liquefied petroleum gas, diesel fuel, gasoline, or any 

other liquid fuel.

[Note 1: These changes make the rule applicable to any engine rated at 50 brake 

horsepower or greater without any reference to the fuel burned.]

B. Exemptions

1. Notwithstanding A.1., tThe requirements of this Rrule shall not apply to:

a. EnginesSpark ignition engines operating on gaseous fuel consisting of 75 percent or more of 

landfill gas on a volume basis determined by annual fuel use. To qualify for this exemption 

written documentation must shall be submitted with the Authority to Construct application to 

and approved by the Control Officer. The documentation must describe the fuel meters

used, and the level of accuracy of the fuel meters, and calculations to correct volumes to 

standard conditions to demonstrate compliance. Separate fuel meters shall be used which 

that measures the volumes (ft3cubic feet) of landfill gas used and a separate fuel meter for 

the volume (ft3) of all other gases gaseous fuel used. Fuel usage records shall be maintained 

identifying the volume of landfill gas and the volume of natural gas all other gaseous fuel 

used annually. The following method shall be used to determine the 75 landfill gas percent 

percentage on a volume basis: 

 Volume in ft3cubic feet of landfill gas consumed annually x 100

 Percent of Fuel use Landfill Gas Percentage =

 Total Volume in ft3cubic feet of all gas gaseous fuel consumed annually

The volumes in the above equation shall be corrected for standard conditions.

[Note 2: These changes add clarity, improve grammar, and correct the equation 

terms.]

b. Engines that are exempt from permit under the provisions of Rules 202, Exemptions to Rule 

201.

[Note 3: This is a minor change for clarity. EPA suggested that this exemption be 

removed for consistency. Instead of deleting this exemption, the APCD has 

achieved consistency by changing the Rule 202 permit exemption threshold (as 

explained further in Appendix A, page A-2, EPA Item 1).]
STAFF REPORT - Regulation II/Rule 333 Page G-2

June 19, 2008

[Annotated draft of June 19, 2008]

Santa Barbara County APCD Rule 333 333 - 2 April 17, 1997[Date of revised rule adoption]

c. Any derated engine having a maximum allowable and enforceable output rating of less than 

50 brake horsepower, provided such rating is specified by the District in an Authority to 

Construct or Permit to Operate and accepted by the engine owner or operator.

[Note 4: Providing an exemption for these engines is consistent with the 

“applicability” provision in the ARB Determination of Reasonably Available 

Control Technology and Best Available Retrofit Control Technology for Stationary 

Spark-Ignited Internal Combustion (ARB RACT/BARCT Determination).]

d. Any compression ignition emergency standby engines, as defined under California Code of 

Regulations, Title 17, Section 93115, Airborne Toxic Control Measure for Stationary 

Compression Ignition (CI) Engines.

[Note 5: The exemption recognizes that these emergency compression ignition 

engines are subject to the state Airborne Toxic Control Measure for Stationary 

Compression Ignition Engines and are low use engines.]

2. Engines which operate Any engine that has a total aggregated operational period less than 200 hours 

per calendar year are is exempt from Sections D., E., F., and G. the requirements of this rule, with the 

exception of the engine identification requirement in Section D.1, the elapsed operating time meter 

requirement in Section D.2, the recordkeeping provisions in Section J.3, and the compliance schedule

provisions in Section K. To qualify for this exemption, the engine owner or operator shall maintain 

and record in a log, as required in Section H, the engine hour meter reading every first working day of 

each calendar quarter.The hours per year operating period of a relocated engine that performs the 

same function as the engine it displaced will be included in calculating the total aggregated operating 

period for determining applicability of this exemption. 

[Note 6A: The Airborne Toxic Control Measure for Stationary Compression Ignition 

Engines (California Code of Regulations, Title 17) Section 93115.3(j) has a low-use 

exemption for prime engines operating no more than 20 hours per year. Thus, a 

compression ignition engine may be exempt from Rule 333, but not the ATCM.]

[Note 6B: The requirements to use an elapsed operating time meter and to perform 

recordkeeping exist in the current rule text (Sections 333.B.2 and 333.H). The 

requirements to provide a method for engine identification, document engine 

relocations, and adhere to a compliance schedule are new. These are added to 

improve substantiation of exemption claims.]

3. Section G requirements for a Compliance Plan shall not be applicable to any compression ignition 

engines that are subject to an exhaust emission standard in the: 

a. California Code of Regulations, Title 13, Section 2423, for off-road engines, or 

b. 40 CFR, Part 89, for nonroad compression ignition engines. 

[Note 7: The APCD has determined that compression ignition engines subject to 

State or Federal requirements in “a” and “b” above do not need a compliance 

plan.]
STAFF REPORT - Regulation II/Rule 333 Page G-3

June 19, 2008

[Annotated draft of June 19, 2008]

Santa Barbara County APCD Rule 333 333 - 3 April 17, 1997[Date of revised rule adoption]

C. Definitions

See Rule 102 for definitions not limited to this rule. For the purpose of this Rrule, the following definitions 

apply:

[Note 8: The addition is made for rule clarification. Numerous engine-related 

terms are being added to Rule 102 because they appear in Rule 202 and Rule 333.]

“Air-balanced pumping engine” means a noncyclically-loaded engine powering a well pump, with the pump 

using compressed air in a cylinder under the front of the walking beam to offset the weight of the column of 

rods and fluid in the well, eliminating the need for counterweights.

[Note 9: This definition is needed to clarify the definition of noncyclically-loaded 

engine.]

“Beam-balanced pumping engine” means a cyclically-loaded engine powering a well pump, with the pump 

counterweight on the back end of the walking beam. The counterweight is moved mechanically without a 

cylinder supplying air pressure.

“Crank-balanced pumping engine” means a cyclically-loaded engine powering a well pump, with the pump 

counterweight attached to a gearbox which is attached to the walking beam with a pitman arm. The 

counterweight is moved mechanically, in a circular motion, without a cylinder supplying air pressure.

[Note 10: The two preceding definitions are needed to clarify the cyclically-loaded 

engine definition.]

“Cyclically-loaded engine” means an engine that under normal operating conditions has an external load that 

varies in shaft load by 40 percent or more of rated brake horsepower during any load cycle or recurrent periods 

of 30 seconds or less, or is used to power an oil a well reciprocating pumping unit including beam-balanced or 

crank-balanced pumps. Engines powering air-balanced pumps are noncyclically-loaded engines.

[Note 11: The APCD is replacing the existing “cyclic engine” term with the 

“cyclically-loaded engine” term and relocating the term to be in alphabetical order. 

The definition has also been revised for clarity. Use of the “cyclically-loaded 

engine” term is consistent with the ARB RACT/BARCT Determination. An engine 

being classified as a cyclically- or noncyclically-loaded engine is strictly dependent 

on its external load in a particular service.]

1. “Engine” means any spark or compression ignited ignition engine in which the pistons are contained 

within a cylinder and move back and forth in a straight line.

2. “Cyclic engine” means an engine that under normal operating conditions varies in shaft load by 40 

percent or more of rated brake horsepower during recurrent periods of 30 seconds or less, or is used to power 

an oil well reciprocating pumping unit. 

[Note 12: The APCD relocated the definition of cyclic engine to put the definitions 

into alphabetical order, changed the term to cyclically-loaded engine, and modified 

the definition.]

3. “Noncyclic engine” means any engine which is not a cyclic engine.
STAFF REPORT - Regulation II/Rule 333 Page G-4

June 19, 2008

[Annotated draft of June 19, 2008]

Santa Barbara County APCD Rule 333 333 - 4 April 17, 1997[Date of revised rule adoption]

[Note 13: The APCD relocated the definition of noncyclic engine to put the definitions 

into alphabetical order, changed the term to noncyclically-loaded engine, and 

modified the definition.]

“Exhaust controls” means any device or technique used to treat an engine's exhaust to reduce emissions, and 

include (but are not limited) to catalysts, afterburners, reaction chambers, and chemical injectors.

[Note 14: The addition of the exhaust controls term is needed to clarify alternative 

compliance provisions available when using an exhaust control (i.e., requirements in 

lieu of meeting the exhaust concentration limits).]

4. “Existing engine” means an engine which that by December 3, 1991 [date of revised rule adoption];

a1. has been issued a valid ATC Authority to Construct, or PTO Permit to Operate, or 

Exemption to a Permit to Operate (or listed as exempt on an Authority to Construct or 

Permit to Operate) pursuant to District rules and regulations; or

b2. has been identified in an application for an ATC Authority to Construct submitted to and 

deemed complete by the District; or

c3. is an identical replacement as defined in Rule 202 A. (5) for an engine defined in Section 

C.4.a.has been operated in Santa Barbara County as exempt and now requires a Permit to 

Operate because of a Rule 202 exemption change effective [date of revised rule 

adoption].

[Note 15: Changes to the above three sections are needed to improve clarity. Also, 

the references to Exemption to a Permit to Operate and listed as exempt on an 

Authority to Construct or Permit to Operate are added to address engines that were 

installed at the time of adoption of the amended rule. The terms new engine and 

existing engine are necessary to determine compliance schedules for this amended 

rule.]

5. “New engine” is an engine which is not an existing engine.

[Note 16: The term new engine is relocated to put the definitions into alphabetical 

order.]

6. “Field gas” means gas which does not meet the standards as published by the Public Utilities 

Commission for natural gas (37 California Code of Regulations 589).

[Note 17: The APCD is deleting this term as it is no longer used in Rule 333.]

“Four-stroke engine” means any type of engine which completes the power cycle in two crankshaft 

revolutions, with intake and compression strokes in the first revolution and power and exhaust strokes in the 

second revolution.

[Note 18: The term “four-stroke engine” is used in the definitions for “lean-burn 

engine” and “rich-burn engine.” Both ARB and EPA noted that a diesel engine is also

a “lean-burn” engine and the existing rule emission limits were not clear. The 

addition of the four-stroke engine term will help clarify the different engine 

classifications and their emission limits.]
STAFF REPORT - Regulation II/Rule 333 Page G-5

June 19, 2008

[Annotated draft of June 19, 2008]

Santa Barbara County APCD Rule 333 333 - 5 April 17, 1997[Date of revised rule adoption]

7. “Lean-burn engine” means a spark-ignited or compression ignited, Otto-cycle, Diesel cycle or 

any two-stroke or four-stroke engine where the manufacturer's recommended operating air-to-fuel ratio 

divided by the stoichiometric air-to-fuel ratio is greater than 1.1. Any existing engine where there are no 

manufacturer‟s recommendations regarding the air-to-fuel ratio will be considered a lean-burn engine if the 

excess oxygen content of the exhaust at full load conditions that is operated with an exhaust stream oxygen 

concentration of is greater than 4 2 percent by volume, or greater. Where exhaust control is employed on 

such an existing engine, The the exhaust gas oxygen content shall be determined from the uncontrolled 

exhaust stream. Any engine modification that changes any rich-burn engine to a lean-burn engine or vice 

versa requires approval from the Control Officer in the form of a permit modification.

[Note 19: The term “lean-burn engine” has been modified to address EPA and ARB 

concerns and definitions.]

“New engine” is an engine that is not an existing engine.

[Note 20: The new engine definition has been relocated to be in alphabetical order.]

"Noncyclically-loaded engine" means any engine which is not a cyclically-loaded engine. 

[Note 21: The APCD relocated the definition of noncyclic engine here, changed the 

term to noncyclically-loaded engine and revised the definition.]

8. “Operating engine” means an engine that is operating and consuming fuel for its intended 

application a minimum of 150 hours for each month during the 12 consecutive month period prior to the 

adoption of this Rule as certified by the engine owner or operator.

[Note 22: The APCD is deleting this term as it is will no longer used in the revised 

Rule 333.]

9. "Rated brake horsepower" means the maximum brake horsepower rating at maximum revolutions 

per minute (RPM) specified for the engine by the manufacturer. Alternately, the rated brake 

horsepower of an engine shall be the maximum allowable and enforceable rating specified by the 

District, stated in the Permit to Operate (PTO), and accepted by the engine operator.

[Note 23: The rated brake horsepower definition is being modified and relocated into 

Rule 102, Definitions.]

“ppmv” means parts per million by volume, dry.

[Note 24: This is a new definition that is added to clarify the units used for mass rate 

emission limits and monitoring/testing results.]

10. “Rich-burn Eengine” means a spark-ignited, Otto-cycle, or a any spark ignition, four-stroke 

naturally aspirated engine where the manufacturer-recommended operating air-to-fuel ratio divided by the 

stoichiometric air-to-fuel ratio is less than or equal to 1.1. Any existing engine where there are no 

manufacturer‟s recommendations regarding the air-to-fuel ratio will be considered a rich-burn engine if the 

excess oxygen content of the exhaust at full load conditions that is operated with an exhaust stream oxygen 

concentration of is less than or equal to 4 2 percent by volume. Where exhaust control is employed on such an 

existing engine, The the exhaust gas oxygen content shall be determined from the uncontrolled exhaust stream. 

Additionally, any engine which is designated as a rich burn engine on a District Permit on the date of rule 

adoption shall be a rich burn engine. Any engine modification that changes any rich-burn engine to a leanburn engine or vice versa requires approval from the Control Officer in the form of a permit modification.
STAFF REPORT - Regulation II/Rule 333 Page G-6

June 19, 2008

[Annotated draft of June 19, 2008]

Santa Barbara County APCD Rule 333 333 - 6 April 17, 1997[Date of revised rule adoption]

[Note 25: The term “Rich-burn engine” has been modified to address EPA and ARB 

concerns and definitions.]

11. “Diesel Engine” means a compression ignited four stroke engine that is operated with an exhaust 

stream oxygen concentration of 4 percent by volume, or greater.

[Note 26: The diesel engine definition is being modified and relocated into Rule 102, 

Definitions.]

“Stoichiometric air-to-fuel ratio” means the chemically correct air-to-fuel ratio where all fuel and all 

oxygen in the air and fuel mixture will be consumed.

[Note 27: The “stoichiometric” term is used in the definitions for “lean-burn engine,” 

“rich-burn engine,” and “two-stroke engine,” which are being revised to address 

ARB and EPA-identified deficiencies.]

“Two-stroke engine” means a type of engine which completes the power cycle in single crankshaft 

revolution by combining the intake and compression operations into one stroke and the power and exhaust 

operations into a second stroke. This system requires auxiliary scavenging and inherently runs lean of the 

stoichiometric air-to-fuel ratio.

[Note 28: This term is used in the definition of “lean-burn engine.”]

D. Requirements – Engine Identification, Meters, and Continuous Monitoring Systems

The owner or operator of any engine subject to this rule shall ensure each engine meets the following 

requirements in accordance with the compliance schedule specified in Section K. 

1. Any engine subject to this rule shall have a permanently affixed plate, tag, or marking listing:

a. the engine's make, model, and serial number; or

b. the owner‟s or operator's unique identification number.

The plate, tag, or marking shall be made accessible and legible.

[Note 29: This section allows for expedited and efficient engine identification.]

2. Each engine shall be equipped with a nonresettable elapsed operating time meter and the meter 

shall be maintained in proper operating condition.

[Note 30: This is a recommendation from the ARB RACT/BARCT Determination.]

3. Each engine shall be equipped with a nonresettable fuel meter or, where approved by the Control 

Officer in writing, an alternative device, method, or technique for determining fuel consumption. 

The fuel meter shall be calibrated periodically pursuant to the recommendations of the 

manufacturer and shall be maintained in proper operating condition.

[Note 31: This is a recommendation from the ARB RACT/BARCT Determination. 

Alternative techniques must be approved by the Control Officer.]
STAFF REPORT - Regulation II/Rule 333 Page G-7

June 19, 2008

[Annotated draft of June 19, 2008]

Santa Barbara County APCD Rule 333 333 - 7 April 17, 1997[Date of revised rule adoption]

4. Engines in the following category shall be equipped with a continuous oxides of nitrogen and 

oxygen monitoring system approved by the Control Officer: 

New engines rated at 1,000 brake horsepower or greater that:

a. are installed on or after [date of revised rule adoption], and

b. are subject to the emission limits specified in Section E, and

c. have Permits to Operate allowing operations in excess of 2,000 hours per year. 

This system shall determine and record exhaust gas oxides of nitrogen concentrations in parts per 

million by volume (dry), corrected to 15 percent oxygen. The continuous monitoring system may 

be a continuous emissions monitoring system or an alternative approved by the Control Officer. 

Alternatives to a continuous emissions monitoring system must be submitted to and approved by 

the Control Officer. Continuous emission monitoring systems shall meet the District Continuous 

Emission Monitoring Protocol (1992) and applicable federal requirements described in 40 CFR 

Part 60. These include the performance specifications found in Appendix B, Specification 2, the 

quality assurance requirements found in Appendix F, and the reporting requirements of Parts 

60.7(c), 60.7(d), and 60.13.

The monitoring system shall have data gathering and retrieval capability as approved by the 

Control Officer. All data collected by the monitoring system shall be maintained for at least two 

years and made available for inspection by the Control Officer. Any Control Officer approved 

continuous monitoring system for oxides of nitrogen, carbon monoxide, and oxygen shall suffice in 

lieu of the quarterly monitoring required in Section F.3.

[Note 32: The continuous monitoring system provisions stem from the ARB 

RACT/BARCT Determination. Based on input from the regulated community, the 

APCD modified the provision to apply to only engines installed on or after the date of 

the revised rule adoption. Quarterly NOx box testing will not be required for engines 

equipped with a continuous monitoring system approved by the APCO.]

DE. Requirements - Emission Limits

Owners or operators of engines shall meet the following requirements based on biennial source testing, in 

accordance with the compliance schedule set forth in Section IK:

[Note 33: The biennial source testing text is unnecessary because compliance with the 

emission limits is not based solely on source testing. Compliance determinations are 

based on various methods, including portable analyzer tests, readings of parameters 

established to show compliance, “method” tests, and, possibly CEMs.]

1. Noncyclic Rich Rich-Burn Noncyclically-Loaded Spark Ignition Engines

a. The emission concentrations, corrected for oxygen, from any such engine Rich burn 

noncyclic engines shall not exceed the following concentration limits corrected for oxygen:
STAFF REPORT - Regulation II/Rule 333 Page G-8

June 19, 2008

[Annotated draft of June 19, 2008]

Santa Barbara County APCD Rule 333 333 - 8 April 17, 1997[Date of revised rule adoption]

Limit (ppmVppmv at 15 percent oxygen) 

Pollutant 15% Oxygen 3% Oxygen

NOx 50 152 

ROC 250 758 

CO 4,500 13,653

[Note 34: The APCD is specifying all emission limit figures corrected to 15% oxygen. 

Thus, all the references to 3% oxygen corrected figures are being deleted. The limits 

shown above are consistent with the ones listed in the ARB RACT/BARCT 

Determination (Table A-1) for the engine classification. However, emission limits in 

federal requirements (40CFR) may be more restrictive and supercede the lessstringent limits specified in Rule 333 for engines subject to the federal provisions.]

b. Rich burn noncyclic engines shall meet Engines using either combustion modifications or 

exhaust controls shall meet the oxides of nitrogen (NOx) requirements limit specified above,

or the oxides of nitrogen (NOx) shall be reduced by at least 90 percent by mass of the 

uncontrolled emissions across the control device. For engines with exhaust controls, the 

percent control shall be determined by measuring concurrently the oxides of nitrogen 

concentration upstream and downstream from the exhaust control. For engines without 

external control devices, the percent control shall be based on source test results for the 

uncontrolled engine and the same engine after the control device or technique has been 

employed. In this situation, the engine‟s typical operating parameters, loading, and duty 

cycle shall be documented and repeated at each successive post-control source test to ensure 

that the engine is meeting the percent reduction limit. The parts per million by volume (dry)

limits for reactive organic compounds and carbon monoxide apply to all engines. 

[Note 35: The alternative compliance method of meeting at least a 90 percent NOx 

reduction for engines using combustion modifications or exhaust controls is consistent 

with the ARB RACT/BARCT Determination (Table A-1).]

2. Noncyclic Lean Lean-Burn Spark Ignition Engines 

a. The emission concentrations, corrected for oxygen, from any such engine Lean burn 

noncyclic engines shall not exceed the following limits as corrected for oxygen:

Any engine with a rated brake horsepower of 50 or greater but less than 100:

Limit (ppmv at 15 percent oxygen)

Pollutant

NOx 200 

ROC 750 

CO 4,500

[Note 36: Including “spark ignition” in the description stems from an EPA-identified 

rule deficiency. In the 1994 Technical Support Document for Rule 333, EPA 

indicated that it is unclear if diesel engines must comply with the 125 ppm limit given 

for lean burn engines or the 797 ppm limit.]

See Note 

37.

See Note 

36.
STAFF REPORT - Regulation II/Rule 333 Page G-9

June 19, 2008

[Annotated draft of June 19, 2008]

Santa Barbara County APCD Rule 333 333 - 9 April 17, 1997[Date of revised rule adoption]

[Note 37: The emission limits for this range of lean-burn spark ignition engines are 

consistent with those in the ARB RACT/BARCT Determination. However, emission 

limits in federal requirements (40CFR) may be more restrictive and supercede the 

less-stringent limits specified in Rule 333 for engines subject to the federal 

provisions.]

Any engine with a rated brake horsepower of 100 or greater:

Limit (ppmVppmv at 15 percent oxygen)

 

Pollutant 15% Oxygen 3% Oxygen

NOx 125 380 

ROC 750 2,275 

CO 4,500 13,653 

b. Lean burn engines shall meetAny engine with a rated brake horsepower of 100 or greater

using either combustion modifications or exhaust controls shall meet the oxides of nitrogen 

(NOx) requirements specified above, or the oxides of nitrogen (NOx) shall be reduced by 

at least 80% percent by mass of the uncontrolled emissions across the control device. For 

engines with exhaust controls, the percent control shall be determined by measuring 

concurrently the oxides of nitrogen concentration upstream and downstream from the 

exhaust control. For engines without external control devices, the percent control shall be 

based on source test results for the uncontrolled engine and the same engine after the control 

device or technique has been employed. In this situation, the engine‟s typical operating 

parameters, loading, and duty cycle shall be documented and repeated at each successive 

post-control source test to ensure that the engine is meeting the percent reduction limit. The 

parts per million by volume (dry) limits for reactive organic compounds and carbon 

monoxide apply to all engines.

[Note 38: The limits and provisions for lean-burn spark ignition engines rated at 100 

brake horsepower or greater are consistent with the ARB RACT/BARCT 

Determination (Table A-1). However, emission limits in federal requirements 

(40CFR) may be more restrictive and supercede the less-stringent limits specified in 

Rule 333 for engines subject to the federal provisions.]

3. Cyclic Rich-Burn Cyclically-Loaded Spark Ignition Engines

a. On or before March 2, 1992 the owner or operator of cyclic engines shall maintain an 

exhaust stream oxygen concentration of 6.5 percent or greater, by volume. Owners or 

operators of cyclic engines shall comply with the following:

i. An initial source test shall be performed within twelve months from December 3, 

1991 for each engine. Subsequent source tests shall be performed in accordance 

with Section G.; and

ii. The exhaust stream oxygen concentration shall be monitored on a monthly basis 

utilizing a portable analyzer or any other method approved by the Control Officer. 

The instrument reading shall be recorded as set forth in Section H.

b. The emission concentrations, corrected for oxygen, from any such engine Cyclic engines 

shall not exceed the following limits, in accordance with Section I.:
STAFF REPORT - Regulation II/Rule 333 Page G-10

June 19, 2008

[Annotated draft of June 19, 2008]

Santa Barbara County APCD Rule 333 333 - 10 April 17, 1997[Date of revised rule adoption]

Limit (ppmVppmv at 15 percent oxygen)

Pollutant 15% Oxygen 3% Oxygen

NOx 50300 152 

ROC 250 758

CO 4,500 13,653

[Note 39: Consistent with the ARB RACT/BARCT Determination and to address 

ARB concerns, the APCD is revising the engine classification terms and the NOx 

emission limit. Emission limits in federal requirements (40CFR) may be more 

restrictive and supercede the less-stringent limits specified in Rule 333 for engines 

subject to the federal provisions,. The APCD is also deleting text that is no longer 

pertinent.]

Alternatively, NOx emissions may be reduced by at least 90% of the uncontrolled emissions 

across the control device.

[Note 40: There is no percent control of NOx provision recommended for this engine 

classification in the ARB RACT/BARCT Determination.]

c. In lieu of D.3.a. and D.3.b. above, an engine owner or operator may choose for any cyclic 

engine to comply with Section D.1. of this rule by designating the cyclic engine as a 

noncyclic engine for the purposes of this Rule. In this case the owner or operator shall notify

the District in writing on or before March 2, 1992 which cyclic engines will be designated as 

noncyclic engines. These engines shall be included as part of the compliance plan as set 

forth in Section F.

[Note 41: The APCD is deleting the above text because it is no longer pertinent and to 

address ARB concerns.]

4. Compression Ignition Engines and Dual-Fuel Engines

a. The emission concentrations, corrected for oxygen, from any such engine Diesel engines 

shall not exceed 8.4 grams per brake horsepower-hour of oxides of nitrogen or the 

following limits as corrected for oxygen:

Limit (ppmVppmv at 15 percent oxygen)

 

Pollutant 15% Oxygen 3% Oxygen

NOx 797700 2,400

ROC 750 

CO 4,500 

[Note 42: EPA pointed out that the 8.4 grams per brake horsepower hour NOx limit 

equates to about 670 ppmv at 15% O2 (assuming 35% efficiency), not the rule’s 797 

ppmv NOx at 15% O2 limit. Thus, the deletion of the 8.4 grams per brake 

horsepower hour limit will eliminate the consistency problem.]

[Note 43: The APCD is basing the new NOx and ROC limits on the Sacramento 

Metropolitan AQMD Rule 412 limits and the CO limit on the Ventura County APCD 

Rule 74.9 limit. The 700 ppmv NOx at 15% oxygen limit is considered a reasonably 

See Note 

42.

See Note 42.

See Note 

43. See Note 

44.
STAFF REPORT - Regulation II/Rule 333 Page G-11

June 19, 2008

[Annotated draft of June 19, 2008]

Santa Barbara County APCD Rule 333 333 - 11 April 17, 1997[Date of revised rule adoption]

available control technology (RACT) limit. The APCD is proposing RACT limits to 

fulfill EPA requirements. However, the NOx emission limits in the Airborne Toxic 

Control Measure for Stationary Compression Ignition Engines (California Code of 

Regulations, Title 17, Section 93115) are more restrictive and, for engines subject to 

the statute, supercede the less-stringent limit specified in Rule 333. Also, emission 

limits in federal requirements (40CFR) may be more restrictive and supercede the 

less-stringent limits specified in Rule 333 for engines subject to the federal 

provisions.]

[Note 44: ARB pointed out that there was confusion over whether the ROC and CO 

limits in Sections 333.D.1 or D.2 applied to diesel engines. They suggested that if 

diesel engines had no ROC or CO limits, this should be stated explicitly in Section 

333.D.4. With the addition of the ROC and CO limits, the APCD has addressed this 

concern.]

b. Engines using either combustion modifications or exhaust controls shall meet the oxides of 

nitrogen limit specified above, or the oxides of nitrogen shall be reduced by at least 40 

percent by mass of the uncontrolled emissions. For engines with exhaust controls, the 

percent control shall be determined by measuring concurrently the oxides of nitrogen 

concentration upstream and downstream from the exhaust control. For engines without 

external control devices, the percent control shall be based on source test results for the 

uncontrolled engine and the same engine after the control device or technique has been 

employed. In this situation, the engine‟s typical operating parameters, loading, and duty 

cycle shall be documented and repeated at each successive post-control source test to ensure 

that the engine is meeting the percent reduction limit. The parts per million by volume (dry)

limits for reactive organic compounds and carbon monoxide apply to all engines.

[Note 45: The APCD is basing the 40 percent NOx reduction figure on the AP-42 

NOx emission factor for uncontrolled compression ignition engines rated less than 

600 brake horsepower (Table 3.3-1) and the new 700 ppmv limit. (The inventory has 

no compression ignition engines rated greater than 600 bhp that are subject to Rule 

333.)]

5. Alternative Emission Control Plan (AECP)

An owner or operator of any existing engine subject to this rule may meet the NOx emission control 

requirements of Sections D.1, D.2, and D.3.b, by controlling additional existing engines at the same 

stationary source, which are not otherwise subject to this rule, provided the owner or operator submits 

an Alternative Emission Control Plan that is enforceable by the District and is approved in writing by 

the Control Officer, ARB and EPA prior to implementation.

Any Alternative Emission Control Plan must be submitted by March 9, 1992.

The Alternative Emission Control Plan shall:

a. Include all information determined by the Control Officer as necessary to confirm that the 

requirements of this section will be met.

b. Include the control of all engines 20 horsepower and larger at the stationary source. All 

engines shall be controlled consistent with the applicable schedule specified in Section I.

c. Achieve at least 20 percent more tonnage of NOx emission reductions than otherwise 

required by Sections D.1, D.2 and D.3.b. The required tonnage of emission reductions shall 
STAFF REPORT - Regulation II/Rule 333 Page G-12

June 19, 2008

[Annotated draft of June 19, 2008]

Santa Barbara County APCD Rule 333 333 - 12 April 17, 1997[Date of revised rule adoption]

be calculated using a 90% (80% for lean burn engines) reduction from an uncontrolled 

emission factor of 2,000 lbs of NOX/MMSCF fuel used, with the baseline fuel usage 

calculated in accordance with Rule 802.F.2. When engine specific fuel usage is not 

available, fuel use data will be apportioned to individual engines based on their estimated 

utilized horsepower, following a method approved by the Control Officer.

d. Specify NOx, ROC and CO ppmv emission limits for each engine. NOx ppmv limits for 

each engine shall be equal to or less than that emitted from the engine when the exhaust 

stream oxygen concentration is set at the maximum percentage achievable while maintaining 

stable engine operation. The ROC and CO ppmv limits specified in Sections D.1, D.2 and 

D.3.b. shall not be exceeded. All engines included in the AECP shall be included as nonexempt engines on District permits with these emission limits specified.

e. Calculate the uncontrolled emission factor for engines 20 to 49 horsepower by measuring the 

NOx emissions in accordance with Section G. (except the test shall be conducted for 30 

minutes) with the exhaust stream oxygen concentration adjusted to 2 percent or greater by 

volume. Baseline fuel usage for these engines shall be calculated as specified above.

f. Calculate the tonnage of emission reductions achieved to meet the requirements of Section 

D.5.c. by subtracting the controlled emission rate from the uncontrolled emission rate. The 

controlled emission rate shall be calculated using the controlled engine NOx ppmv limit and 

the baseline fuel usage. The uncontrolled emission rate shall be calculated as specified in 

Section D.5.c for engines 50 horsepower and over and Section D.5.e for engines 20 to 49 

horsepower.

g. Provide that emission reductions for any engine required under Regulation VIII shall not be 

used to reduce the emission reductions required of any other engine.

h. Include engine specific fuel usage monitoring, and other continuous monitoring on each 

engine determined necessary by the Control Officer to confirm continuous compliance with 

the required pollution reductions.

i. Exempt from the requirements of Section G and D.5.h., any 20 to 49 horsepower engines 

whose control is not required to meet the obligations established under Section D.5.c. These 

engines must, however, meet all other requirements in the rule, including requirements in 

Section E. The AECP shall specify any engines subject to this exemption.

j. Insure compliance with all other provisions of this rule, including but not limited to D.3.a, 

D.4 and D.5.

The AECP may be modified at a future date to incorporate equivalent replacement engines which 

meet the requirements of Rule 202.D.9. The emission limit for the new engine shall be the same as 

for the replaced engine.

All District costs for the review and enforcement of the AECP and for District participation in any 

field studies shall be reimbursed under the cost reimbursement provisions of Rule 210.

A violation of the AECP shall be a violation of this rule and any applicable permit.

[Note 46: The deletion of the entire Alternative Emission Control Plan section is 

consistent with a recommendation by EPA and will eliminate an outdated provision. 

The March 9, 1992 deadline for submitting an AECP has passed, no sources ever 

submitted an AECP, and no such plans are currently in effect.]
STAFF REPORT - Regulation II/Rule 333 Page G-13

June 19, 2008

[Annotated draft of June 19, 2008]

Santa Barbara County APCD Rule 333 333 - 13 April 17, 1997[Date of revised rule adoption]

65. The use of anhydrous ammonia to meet the requirements of this rule is prohibited unless case-specific 

analysis indicates that the use is acceptable to the Control Officer.

[Note 47: Adding the case-specific provision will allow future analysis (including 

CEQA analysis) to address the acceptability of using anhydrous ammonia for a 

control technique.]

EF. Requirements - Owner or Operator Engine Inspections and Maintenance Plan

All Any engines subject to the requirements of Section D E shall be inspected by the engine owner or operator 

in accordance with a District District-approved engine Engine inspection Inspection and maintenance 

Maintenance plan Plan for each stationary source. which The owner or operator shall meet the following 

requirements for the Plan in accordance with the compliance schedule specified in Section K:

1. The plan shall be submitted to the District by March 2, 1992. Obtain the Control Officer‟s approval

of the Plan. An Inspection and Maintenance Plan for each stationary source shall be submitted to the 

District in a format approved by the Control Officer.

[Note 48: Per the recommendations in the ARB RACT/BARCT Determination, 

engine owners and operators are to implement an Inspection and Maintenance Plan 

(I&M Plan) as part of the Emission Control Plan requirements. Section K.2.d.ii.1) 

requires the owners and operators of any existing engine subject to the emission limits 

to submit a new/revised I&M Plan no later than six months from the date of the 

revised rule adoption.]

2. Such plan shall list List all engines by engine classification, identified as either cyclics (rich-burn 

noncyclically-loaded spark ignition, rich-burn cyclically-loaded spark ignition, lean-burn spark 

ignition, and noncyclicscompression ignition, or dual-fuel), and identify the method, engine and 

control equipment operating parametersparameter ranges, and compliance values, including engine 

exhaust oxygen concentration ranges, to be used to verify compliance with Section DE.

[Note 49: The ARB RACT/BARCT Determination recommends that engine owners 

and operators establish ranges for control equipment parameters, engine operating 

parameters, and engine exhaust oxygen concentrations that source testing has shown 

results in pollutant concentrations within the rule limits. This data will be used 

during the inspections required by the I&M Plan to ensure that the equipment is 

operating correctly.]

3. The plan shall require a minimum of one inspection for each engine every calendar quarter. The 

readings for each parameter identified in E.2. shall be recorded pursuant to Section H.

[Note 50: The current “quarterly inspection and monitor reading recordkeeping” 

requirements of Subsection 3 are being integrated into other sections. Hence, the 

current provisions in Section 3 are deleted and Subsection 4 will be renumbered as 3.]
STAFF REPORT - Regulation II/Rule 333 Page G-14

June 19, 2008

[Annotated draft of June 19, 2008]

Santa Barbara County APCD Rule 333 333 - 14 April 17, 1997[Date of revised rule adoption]

43. A portable NOx emissions analyzer or any other method approved by the Control Officer shall be 

used to take NOx oxides of nitrogen and carbon monoxide emission readings and engine exhaust 

oxygen concentration readings to determine compliance with the emission limits or percent control 

specified in Section D E during which any quarter (or month, if performing monthly monitoring) in 

which a source test is not performed under Section G I and an engine is operated in excess of 20 hours

per quarter. If such an engine cannot be operated for portable analyzer emissions testing due to 

mechanical failure or lack of fuel, the monitoring requirement may be waived provided written 

Control Officer approval is obtained prior to the end of the quarter (or month, if performing monthly 

monitoring). All emission readings shall be taken at an engine‟s typical duty cycle.The results shall 

be recorded pursuant to Section H. The analyzer shall be calibrated, maintained, and operated in 

accordance with the manufacturer‟s specifications and recommendations or a Control Officer 

approved protocol. The applicable control equipment parameters and engine operating parameters 

will be inspected and monitored in conformance with a regular inspection schedule listed in the Plan. 

An portable analyzer instrument reading in excess of the emission compliance values shall not be 

considered a violation of this rule, so long as the problem is corrected engine is brought into 

compliance and a follow-up inspection is conducted within 15 days of the initial inspectionout-ofcompliance reading. If an engine owner or operator or district staff find an engine to be operating 

outside the acceptable range for control equipment parameters, engine operating parameters, engine 

exhaust oxides of nitrogen or carbon monoxide concentrations, the owner or operator shall bring the 

engine into compliance within 15 days. Also, when there has been a portable analyzer instrument 

reading in excess of the emission compliance value or a source test result in excess of an emission 

limit or less than the percent control requirement, the inspection and maintenance monitoring 

schedule will be performed on a monthly basis and continue to be monthly until Rule 333 compliance 

is demonstrated in three consecutive months (by portable analyzer or source tests).

[Note 51: The text on “NOx Analyzer” is being revised to be “emissions analyzers” to 

take into account that the instrument needs to measure NOx, CO, and the oxygen 

concentration to provide compliance data corrected for oxygen. The or any other 

method approved by the Control Officer text is being deleted to simplify the rule. 

Exhaust oxygen concentrations need to be determined to correct the NOx and CO 

emission readings to the 15% O2 standard.] 

[Note 52: The APCD is proposing that the inspections required by I&M plans 

continue to be on a quarterly basis. However, if the engine or its control equipment is 

found to be operating outside an acceptable range, parameter, or NOx/CO emission 

limit, the monitoring frequency will be changed to a monthly basis. The monthly 

frequency will continue until there are three months of monitoring results 

demonstrating compliance.] 

[Note 53: The in excess of 20 hours per quarter provision is added to waive the 

monitoring requirements for engines that have low usage or that are out of service. 

Also, owners and operators of engines encountering mechanical failures or lack of 

fuel may seek a waiver on the monitoring requirement. The APCD added these 

provisions based on input from Industry.]

[Note 54: During an annual or biennial comprehensive source test, it is the APCD 

practice to test emission units at the maximum load feasible. At a minimum, source 

test loads must reflect loads representative of typical operations. For a monthly or 

quarterly I&M, the APCD will accept tests performed at an engine’s typical duty 

cycle.]

See Note 

51.

See Note 

52.

See Note 

52.

See Note 

53.

See Note 

54.

See Note 

55.

See Note 

56.

See Note 

57.
STAFF REPORT - Regulation II/Rule 333 Page G-15

June 19, 2008

[Annotated draft of June 19, 2008]

Santa Barbara County APCD Rule 333 333 - 15 April 17, 1997[Date of revised rule adoption]

[Note 55: This text is from the ARB RACT/BARCT determination (except the 

reference to monthly monitoring was removed).]

[Note 56: These text changes are made for clarity.]

[Note 57: This provision is added to clarify that there is a 15-day period to bring a 

noncompliant engine into compliance.]

The results and instrument readings for each engine and control equipment operating parameter 

identified in the inspection plan Inspection and Maintenance Plan, the analyzer instrument readings, a 

description of the corrective actions taken, a determination of whether or not the engine is in 

compliance, and the initials name of the person recording the measurement information shall be 

recorded on in an inspection log consistent with the recordkeeping provisions specified in Section J.1. 

[Note 58: The APCD is changing the provision from recording initials to name to 

improve accountability. Also, the cross-reference to the recordkeeping provisions in 

Section J.1 is included for consistency.]

4. Include preventive and corrective maintenance procedures. Before any change in operations can be 

implemented, the Plan must be revised as necessary, and the revised Plan must be submitted to and 

approved by the Control Officer.

[Note 59: The new number 4 and plan change provisions are consistent with those 

specified in the ARB RACT/BARCT Determination (§VII.A(2)).]

FG. Requirements - Compliance Plan

[Note 60: The ARB RACT/BARCT Determination recommends that engine owners 

and operators subject to the emission limits submit an “Emission Control Plan.” 

These plans are what the APCD refers to as a “Compliance Plan” in Rule 333.

A compliance The owner or operator of any engine subject to the emission limits in Section E shall submit and 

obtain the Control Officer‟s approval of a Compliance planPlan. A new or revised Compliance Plan for each 

stationary source shall be submitted to the District in a format approved by the Control Officer in accordance 

with the time schedule specified in Section I.2. K unless otherwise specified by the Control Officer. or I.3. to 

the District for each stationary source The Compliance Plan shall describe all actions, including a schedule of 

increments of progress, which will be taken to meet the applicable emissions limitations in Section E and the 

compliance schedule in Section K. The owner or operator shall ensure that the Compliance Plan meets the 

following requirements and shall include:

[Note 61: The APCD added the any engine subject to the emission limits in Section E

text to clarify that only engines subject to the Rule 333 emission limits require a 

Compliance Plan.]

[Note 62: This language is included to allow APCO discretion on the submittal of 

revised I&M and Compliance Plans.]

[Note 63: This is the same text found in the ARB RACT/BARCT Determination 

(§VII.A(1)).]

See Note 

61.

See Note 

62.

See Note 

63.
STAFF REPORT - Regulation II/Rule 333 Page G-16

June 19, 2008

[Annotated draft of June 19, 2008]

Santa Barbara County APCD Rule 333 333 - 16 April 17, 1997[Date of revised rule adoption]

1. a lList of all engines with by classification (rich-burn noncyclically-loaded spark ignition, rich-burn 

cyclically-loaded spark ignition, lean-burn spark ignition, compression ignition, or dual-fuel),

make, model, serial number (or owner‟s/operator's ID number), rated brake horsepower and 

associated RPM, type of fuel (including higher heating value and percent or ppm parts per million by 

volume (dry) sulfur), engine application, maximum total hours of operation per in the previous year, 

typical daily operating schedule, fuel consumption (cubic feet of gas or gallons of liquid) for the 

previous one year period, engine location and engine PTO Permit to Operate number(if applicable);.

and

[Note 64: Specifying the engine classification is important to establish the applicable 

Rule 333, Section E emission limits.]

[Note 65: The APCD is adding owner’s on the engine identification provision for 

consistency with Rule 333.D.1.]

[Note 66: Providing the information for each engine is consistent with a 

recommendation in the ARB RACT/BARCT Determination.]

2. List manufacturer-tested typical emission rates or source test values, if available or documentation 

showing existing emissions of oxides of nitrogen, reactive organic compounds, and carbon 

monoxide;. and

[Note 67: The ARB RACT/BARCT Determination, Section VII.A(1)(k) recommends 

that the documentation on the existing emissions of NOx, VOC, and CO be provided.]

3. List the applicable emission limits.

[Note 68: Reference the ARB RACT/BARCT Determination, Section VII.A(1)(j).]

34. List the type of emission control device or method for each engine, and the temperature and flow rate 

of the exhaust gas, and any auxiliary devices used with the main control device (i.e., air-to-fuel ratio 

controller, exhaust gas monitor, etc.), and the proposed installation completion date for each engine to 

be controlled, stack modifications to facilitate continuous in-stack monitoring and source testing. 

[Note 69: Providing the stack modification data is consistent with the ARB 

RACT/BARCT Determination, Section VII.A(1)(i).]

5. An Engine Inspection and Maintenance Plan, as specified in Section F, or at a minimum, a reference 

to and a statement incorporating the Engine Inspection and Maintenance Plan into the Compliance 

Plan.

[Note 70: Section VII.A(2) of the ARB RACT/BARCT Determination recommends 

that the Emission Control Plan include the I&M Plan.]

46. List of all existing and operating engines planned for shutdown or electrification and the proposed 

date of shutdown or electrification.

[Note 71: The and operating engine text is no longer used in this rule.]

An owner or operator may modify a compliance Compliance plan Plan by submitting a modified plan to the 

District at least thirty (30) calendar days prior to modifying the equipment, or control method or compliance 

See Note 

64.

See Note 

65.

See Note 

66.
STAFF REPORT - Regulation II/Rule 333 Page G-17

June 19, 2008

[Annotated draft of June 19, 2008]

Santa Barbara County APCD Rule 333 333 - 17 April 17, 1997[Date of revised rule adoption]

date for any engine. Modification of a compliance plan shall not alter the schedule of controlled horsepower 

required in Section I.

Approval of a compliance Compliance plan Plan does not relieve the owner or operator of engine(s) from the 

permitting requirements of District Rule 201.

[Note 72: These changes are made for consistency with other parts of the rule and for 

improved rule clarity.]

H. [Reserved]

[Note 73: A previously proposed Section H covered the requirements for a Heat 

Input Verification Plan, which was integral to an earlier proposed Section B.3 

exemption. The APCD proposed requirements to demonstrate that an engine rated

greater than 50 brake horsepower operates at all times below 50 brake horsepower. 

After discussing the need for the exemption, Industry and APCD staff decided that 

the proposed exemption and its related plan could be deleted. Rather than revise the 

previously assigned alphabetical designations of the successive rule sections, the 

APCD elected to simply “reserve” Section H.]

GI. Requirements - Source Testing

The owner or operator of any engine subject to the requirements of Section E shall comply with the following:

[Note 74: The APCD added the lead-in sentence to clarify that only engines subject to 

the Rule 333 emission limits are subject to the source testing provisions.]

1. Source test plans Except as otherwise provided in Section I.8, an initial emissions source test shall be 

performed on each stationary internal combustion engine to verify compliance with Section E. A 

After the initial source test, source tests shall be performed biennially to demonstrate compliance with 

Section DE. SThese source tests shall be performed within 30 calendar days of the anniversary date 

of the initial source test, unless the Control Officer approves a period longer than thirty (30) calendar

days. Emissions source testing shall be conducted at an engine's maximum achievable load or, at a 

minimum, under the engine's typical duty cycle as demonstrated by historical operational data. 

Source test loads shall be finalized in the source test plan approved by the District per Section I.2. 

For facilities with more than 20 engines subject to Section E requirements, the Control Officer may, 

on a case-by-base basis, approve a source‟s written request to exclude one or more engines from 

biennial testing. Such a request shall be submitted with the Plan required in Section I.2. 

[Note 75: Section VII.B(1)(c) of the ARB RACT/BARCT Determination recommends 

that the source testing requirements include a provision on an initial source test.]

[Note 76: These provisions are currently in existing Rule 333, Section G.1.b. Staff 

relocated the 1.b biennial source testing requirements into the above paragraph and 

renumbered the subsections.]

[Note 77: The maximum achievable load or typical duty cycle have historically been 

addressed in the permit conditions and determined during the Source Test Plan 

review process.]

See Note 

75.

See Note 

76.

See Note 77.
STAFF REPORT - Regulation II/Rule 333 Page G-18

June 19, 2008

[Annotated draft of June 19, 2008]

Santa Barbara County APCD Rule 333 333 - 18 April 17, 1997[Date of revised rule adoption]

 2. a. An owner or operator of any engine shall A source test plan shall be submitted to the District 

and obtain the Control Officer's approval of a source test planshall be obtained prior to the start of a 

source test. The approved plan shall be on filed with the District at least thirty (30) calendar days 

before the start of each source testing. The District shall be notified of the date for source testing an 

engine at least fourteen (14) calendar days prior to testing to arrange a mutually agreeable test date. 

In addition to other information, the source test plan shall describe which critical parameters will be 

measured, and how the ranges for these parameters shall be established and incorporated into the 

Engine Inspection and Maintenance Plan described in Section F. 

[Note 78: These requirements are consistent with provisions recommended in the 

ARB RACT/BARCT Determination, Section VII.B(1)(c).]

b. A source test shall be performed biennially to demonstrate compliance with Section D. 

Source tests shall be performed within 30 calendar days of the anniversary date of the initial 

source test, unless the Control Officer approves a period longer than thirty (30) calendar 

days.

[Note 79: The APCD moved the biennial source testing frequency provision into 

Section I.1, above.]

3. c. Source testing shall be performed by a source test contractor certified by the California Air 

Resources Board. District required Ssource testing shall not be performed by a source owner or 

operator unless approved by the Control Officer.

[Note 80: These changes are made for clarity.]

4. For each source test performed, a Source Test Report shall be submitted to the District within 45 days 

of completing the test. Reactive Organic Compounds, oxides of nitrogen, and carbon monoxide 

concentrations shall be reported in parts per million by volume, corrected to 15 percent oxygen. For 

engines using either combustion modifications or exhaust controls, oxides of nitrogen shall be 

reported as a percent reduction from the combustion modification or control device.

[Note 81: This is being added for clarity]

5. d. The owner or operator of For any engine which that is found not to be in compliance with 

Section DE. as a result of source testing, shall comply with the following shall apply:

a. i. A rRepeat a source test shall be performed to demonstrate compliance with Section 

D.E within the time period specified by the District.

b. ii. Notwithstanding the provisions of Section G.1.b.I.1, annual source tests shall be 

conducted on any noncompliant engine until two consecutive annual tests demonstrate the 

engine is in compliance with Section D E. When the engine is demonstrated to be 

compliance with Section D E by two consecutive annual source tests, the engine shall 

comply with the provisions of Section G.1.bI.1.

[Note 82: These changes are made for consistency with other parts of the rule and for 

improved rule clarity.]

26. Engine operating parameters (e.g., timing, manifold vacuum pressure, valve set points, etc.) shall be 

established using the results of the source test carried out pursuant to Section GI.1.

37. Test Methods
STAFF REPORT - Regulation II/Rule 333 Page G-19

June 19, 2008

[Annotated draft of June 19, 2008]

Santa Barbara County APCD Rule 333 333 - 19 April 17, 1997[Date of revised rule adoption]

 a. Source testing shall be performed in accordance with the following procedures:

NOx, CO, O2: CARB Method 1-100

ROC: EPA Method 18 or EPA Method 25

i. Stack gas oxygen: Environmental Protection Agency Method 3A or Air Resources 

Board Method 100.

ii. Nitrogen oxides: Environmental Protection Agency Method 7E or Air Resources 

Board Method 100.

iii. Carbon monoxide: Environmental Protection Agency Method 10 or Air Resources 

Board Method 100.

[Note 83: In ARB’s 1992 comments on Rule 333, ARB recommended that the source 

test method be changed from CARB Method “1-100” to “100.” Including the 

alternative EPA Methods 3A, 7E, and 10 is consistent with the ARB RACT/BARCT 

Determination.]

iv. Reactive organic compounds: Environmental Protection Agency Method 18 with 

gas chromatography-flame ionization detection speciation analysis for C1, C2, C3, 

C4, C5, C6+ species.

[Note 84: ARB pointed out that the rule should require the EPA Method 25 (for 

determination of total organics) “and” the EPA Method 18 (for determination of 

exempt compounds), not “or” as currently written. ARB’s basis for this 

recommendation was that the two EPA methods are not alternatives; they are used in 

combination to determine ROC emissions corrected for exempt compounds (nonROCs). 

The APCD has chosen EPA Method 18 as it allows for subtracting “exempt 

compounds” from the total organic compound measurement.]

v. Pollutant Mass Emission Rate (e.g., pounds per hour): Calculated from stack flow 

rate data obtained by either 1) the Environmental Protection Agency Methods 1 

through 4, or 2) the Environmental Protection Agency exhaust concentration, fuel 

flow and fuel composition data as per EPA Method 19 , Sections 2.1 and 3.2.1.

stack flow rate F factor (ratio of combustion gas volume to heat input), using fuel 

flow and fuel composition data.

[Note 85: The pollutant mass emission rate test methods data is being relocated here 

to group the “method” tests together.]

vi. Fuel rate: Appropriate District-approved metering system, calibrated 

within 60 days of the test date. Public utility company regulated utility fuel meters 

relied on by operators for testing may be allowed an alternative calibration 

schedule per the Control Officer‟s discretion. Results must be corrected for 

temperature and pressure (standard conditions of 60°F and 29.92 inches of 

Mercury.
STAFF REPORT - Regulation II/Rule 333 Page G-20

June 19, 2008

[Annotated draft of June 19, 2008]

Santa Barbara County APCD Rule 333 333 - 20 April 17, 1997[Date of revised rule adoption]

[Note 86: Adding District-approved clarifies that the metering system needs to meet 

the APCD’s standards. Some sources rely on PUC meters, which are calibrated 

under different schedules with rigorous protocols. Thus, the APCD may allow the 

calibration window to extend beyond 60 days before the source test for such meters. 

The text on temperature and pressure is not necessary as the standard condition 

definition in Rule 102 defines them.]

vii. Determination of the Fuel Composition and Higher Heating Value: The following 

applicable standards developed by ASTM International: ASTM Method 

1) ASTM D- 1945-8103, “Standard Test Method for Analysis of Natural 

Gas by Gas Chromatography,” ASTM International,

2) ASTM Method D- 3588-8198 (2003), “Standard Practice for Calculating 

Heat Value, Compressibility Factor, and Relative Density of Gaseous 

Fuels,” ASTM International, and 

3) ASTM Method D- 1072-80.06, “Standard Test Method for Total Sulfur 

in Fuel Gases,” ASTM International,

4) ASTM D 240-02 (2007), “Standard Test Method for Heat of 

Combustion of Liquid Hydrocarbon Fuels by Bomb Calorimeter,” 

ASTM International,

5) ASTM D 4809-06, “Standard Test Method for Heat of Combustion of 

Liquid Hydrocarbon Fuels by Bomb Calorimeter (Precision Method),” 

ASTM International, and

6) ASTM D 1826-94 (2003), “Standard Test Method for Calorific 

(Heating) Value of Gases in Natural Gas Range by Continuous 

Recording Calorimeter,” ASTM International.

The Control Officer may approve in writing alternative methods for determining 

the fuel composition or fuel higher heating value.

[Note 87: The APCD has included ASTM International methods typically used for 

fuel composition and the fuel’s HHV analysis. The last provision on the APCOapproved alternative methods is included to allow use of other ASTM International 

methods or other similarly acceptable methods that a source may propose.]

Pollutant Emission Rate: Calculated from exhaust concentration, fuel flow and fuel 

composition dataas per EPA Method 19, Sections 2.1 and 3.2.1.

[Note 88: The pollutant mass emission rate provision is moved to Section I.7.a.v and 

it is being modified for improved rule clarity.]

b. The Control Officer may approve in writing an alternative source test method provided that 

such method is comparable in accuracy to the procedure in G.3.a I.7.a and has been 

approved by the ARB Air Resources Board and the EPA Environmental Protection Agency.

[Note 89: These changes are made for consistency with other parts of the rule and for 

improved rule clarity.]
STAFF REPORT - Regulation II/Rule 333 Page G-21

June 19, 2008

[Annotated draft of June 19, 2008]

Santa Barbara County APCD Rule 333 333 - 21 April 17, 1997[Date of revised rule adoption]

c. At a minimum, three 30 minute test runs shall be performed, and the average concentration 

from the three runs shall be used for determining compliance unless alternative provisions 

are specified in an approved source testing plan.

[Note 90: The ARB RACT/BARCT Determination for Spark Ignition Engines 

specifies the following when indicating the RACT and BARCT limits: 

[. . .] emissions, corrected to 15 percent oxygen on a dry basis and averaged 

over 15 minutes, shall not exceed the following limits for the appropriate 

engine type:

However, based on industry input, the APCD agreed to use a 30 minute averaging 

time instead of the 15 minute period recommended by ARB.] 

8. Initial and biennial source testing requirements shall not be applicable to any compression ignition 

engines that are subject to an exhaust emission standard in the: 

a. California Code of Regulations, Title 13, Section 2423, for off-road engines, or 

b. 40 CFR, Part 89, for nonroad compression ignition engines. 

However, a source test shall be triggered for such engine if the result from a portable analyzer 

emissions monitoring reading (e.g., a result obtained during the monitoring required by Section F.3) 

exceeds a threshold of 560 parts per million of oxides of nitrogen at 15 percent oxygen, unless the 

engine is brought into compliance with this threshold value and a follow-up portable analyzer 

monitoring inspection is conducted within 15 days of the initial over-the-threshold reading. 

The owner or operator of the engine shall provide written notification to the Control Officer within 

two business days of a portable analyzer emissions monitoring reading in excess of the 560 parts per 

million of oxides of nitrogen at 15 percent oxygen threshold. In addition, portable analyzer 

monitoring results shall be reported to the APCD within three business days of any follow-up 

quarterly portable analyzer monitoring. 

Source testing of a Tier 1, 2, 3 or 4 engine, if triggered per the above criteria, shall be completed 

within 60 days of the initial over-the-threshold reading and shall comply with Sections I.2, I.3, I.4, 

I.5.a, and I.7. 

Any compression ignition engine that triggers a source test, and demonstrates compliance with the 

oxides of nitrogen standard in Section E.4, shall not be subject to another source test for two years 

from the date of the initial compliant source test. Any compression ignition engine that does not 

comply with the oxides of nitrogen standard in Section E.4 based on any source test, shall thereafter 

be subject to source testing on a biennial schedule starting from the date of the initial failed source 

test. 

[Note 91: The new Section I.8 provisions are being added to provide an exemption to 

diesel engines complying with the ARB/EPA tier limits. By adding this exemption 

for the ARB/EPA tiered engines, the APCD avoids requiring source tests on these 

engines.] 

[Note 92: The APCD decided on the 560 ppmv at 15 percent oxygen threshold since 

this level indicates the NOx Tier certification is not holding, and emissions levels could

potentially be above the applicable emission limit considering the uncertainty of the 

portable analyzer.]

See Note 

92.
STAFF REPORT - Regulation II/Rule 333 Page G-22

June 19, 2008

[Annotated draft of June 19, 2008]

Santa Barbara County APCD Rule 333 333 - 22 April 17, 1997[Date of revised rule adoption]

HJ. Recordkeeping

1. The owner or operator of any engine subject to the requirements of this rule Section E shall maintain a 

written engine Engine operation Operation, Inspection, and Maintenance log Log containing the 

following information for each engine subject to an emission limit: 

[Note 93: The APCD added the subject to the requirements of Section E text to clarify 

that only engines subject to the Rule 333 emission limits are subject to the Engine 

Operation, Inspection, and Maintenance Log requirements.]

a). Engine classification (rich-burn noncyclically-loaded spark ignition, rich-burn cyclicallyloaded spark ignition, lean-burn spark ignition, compression ignition, or dual-fuel), make, 

model, and serial number or the owner‟s or operator‟s unique identification number.

[Note 94: Indication of the engine’s classification, make, model, and serial number or 

the owner’s/operator’s unique ID number is important for tracking purposes. (If the 

owner or operator chooses to use the APCD’s device identification number that 

would suffice to fulfill the owner’s or operator’s unique identification number

requirement.)]

b. hHours of operation, as determined by a nonresettable elapsed operating time meter, each 

month for each engine since the last inspection; .

[Note 95: Proposed amended Rule 333, Section D.2, requires that each engine subject 

to the rule be equipped with a nonresettable elapsed operating time meter. The each 

month recording frequency is being changed to since the last inspection because the 

I&M Plan monitoring frequency is quarterly for compliant engines.]

b)c. lLocation and hours of engine operation of the engine as determined by an hour meter for 

each engine which operates less than 200 hours per calendar year.

[Note 96: The recordkeeping provision on the operating hours for engines operating 

less than 200 hours per year is being moved to a separate section (Rule 333.J.3). 

Thus, the text is being deleted from the above section.]

c)d. a A summary of any maintenance performed on an emission control device;.

d)e. a A summary of any maintenance performed on an engine which that affects the emission 

control device.; and,

e)f. the oObservations made in during each monthly or quarterly inspection, pursuant to the 

requirements of Section E F.3.

[Note 97: The changes in the above three sections are made for consistency with other 

parts of the rule and for improved rule clarity.]

g. Date of each log entry and the printed or typed name of the person entering the log 

information.

[Note 98: Documenting the date of each log entry is important for verifying 

compliance with the Section F.3 periodic I&M monitoring requirement. Requiring 
STAFF REPORT - Regulation II/Rule 333 Page G-23

June 19, 2008

[Annotated draft of June 19, 2008]

Santa Barbara County APCD Rule 333 333 - 23 April 17, 1997[Date of revised rule adoption]

that the person performing the monitoring/inspection print or type their name is 

needed to ensure accountability.]

h. For every engine that has been relocated, a notation to that effect identifying both the 

present and prior location, the reason(s) for the engine relocation, and the elapsed 

operating time meter readings for both the relocated engine and the engine being 

displaced.

[Note 99: Details on relocated and displaced engines help verify compliance with 

Permit conditions.]

2. Copies of all engine Engine Operation, inspectionInspection, and maintenance Maintenance logs Logs 

shall be retained by the operator for a minimum of 2 years after the date of the last entry and shall be 

available to the District upon request. Thereafter, the Logs shall be retained for an additional 3 years

either at the stationary source or in a readily available location that allows for expeditious District 

inspection and review.

[Note 100: The new additional 3 year log retention provision is made to comply with 

an EPA policy.]

3. For any exemption claimed under Section B.2, maintain a written Engine Exemption Log 

containing the following information for each engine subject of the claim in accordance with the 

compliance schedule in Section K:

a. Engine‟s classification (rich-burn noncyclically-loaded spark ignition, rich-burn 

cyclically-loaded spark ignition, lean-burn spark ignition, compression ignition, or dualfuel), make, model, and serial number or the owner‟s or operator‟s unique identification 

number.

[Note 101: Sources claiming the Rule 333.B.2 exemption need to comply with the 

Rule 333.D.1 engine identification requirement. Indication of the engine’s make, 

model, and serial number or the owner’s/operator’s unique ID number is important 

for compliance and tracking purposes. (If the owner or operator chooses to use the 

APCD’s device identification number that would suffice to fulfill the owner’s or 

operator’s unique identification number requirement.)]

b. Hours of operation per quarter (or more often at the owner‟s or operator‟s discretion), as 

determined by a nonresettable elapsed operating time meter.

[Note 102: Requiring the engine owner or operator to record the engine operating 

hours provides a method for verifying compliance with the 200 hours per year 

threshold.]

c. Location of operation of the engine.

[Note 103: Documenting the location of the engine is necessary for inventory and 

compliance purposes.]

d. Date of each log entry and the printed or typed name of the person entering the log 

information.

[Note 104: Documenting the date of each log entry is important for verifying 

compliance with these recordkeeping provisions. Requiring that the person 
STAFF REPORT - Regulation II/Rule 333 Page G-24

June 19, 2008

[Annotated draft of June 19, 2008]

Santa Barbara County APCD Rule 333 333 - 24 April 17, 1997[Date of revised rule adoption]

performing the monitoring/inspection print or type their name is needed to ensure 

accountability.]

e. For every engine that has been relocated, a notation to that effect identifying both the present 

and prior location, the reason(s) for the engine relocation, and the elapsed operating time 

meter readings for both the relocated engine and the engine being displaced.

[Note 105: Details on relocated and displaced engines help verify compliance that the 

200 hours per year threshold is not being exceeded.]

At a minimum, entries in the Engine Exemption Log shall be performed on the first day the engine is 

operated in a new quarter and when any engine is relocated. Copies of all such Logs shall be retained 

at the stationary source for a minimum of 2 years after the date of the last entry and shall be available 

to the District upon request. Thereafter, the Logs shall be retained for an additional 3 years either at 

the stationary source or in a readily available location that allows for expeditious District inspection 

and review.

[Note 106: Industry has indicated that under the existing recordkeeping provisions 

they had to log the operating hours on an engine each quarter irrespective that the 

engine had not operated during the reporting period. Thus, the APCD is adding the 

first day the engine is operated in a new quarter to avoid unnecessary recordkeeping.]

[Note 107: This retention provision complies with an EPA policy on maintaining 

records for five years.]

IK. Compliance Schedule

The owner or operator of any engine subject to this rule shall meet the following compliance schedule:

1. New engines: shall comply with this rule on the date of adoption.

Commencing [date of revised rule adoption], any new engine shall comply with this rule the first time 

it is operated in the District or the outer continental shelf for which the District is the corresponding 

onshore area. 

[Note 108: The owner or operator of any new engine will need to comply with the 

requirements for engine identification, metering, and the I&M and Compliance Plans 

the first time the engine is operated in the APCD’s jurisdiction.] 

2. Owners or operators of existing noncyclic engines shall comply as follows:

a. by March 2, 1992 submit a Compliance Plan pursuant to Section F.; and

b. by September 3, 1992 control a sufficient number of engines to meet the requirements of 

Section D. for a minimum of 33% of the total rated brake horsepower of the engines at the 

stationary source; and

c. by June 3, 1993 control a sufficient number of engines to meet the requirements of Section 

D. for a minimum of 66% of the total rated brake horsepower of the engines at the stationary 

source; and

d. by March 8, 1994 control a sufficient number of engines to meet the requirements of Section 

D. for all engines.

See Note 

106.

See Note 

107.
STAFF REPORT - Regulation II/Rule 333 Page G-25

June 19, 2008

[Annotated draft of June 19, 2008]

Santa Barbara County APCD Rule 333 333 - 25 April 17, 1997[Date of revised rule adoption]

3. Owners or operators of existing cyclic engines shall comply as follows:

a. by March 2, 1992 meet the requirements of Section D.3.a.

b. Within one year or sooner from date of adoption the Board of Directors of the Air Pollution 

Control District shall notice a public hearing at least thirty (30) days prior to the hearing 

date. The hearing will be held to review additional information pertaining to the 

requirements of Section D.1., D.2. and D.3.b.

c. by March 3, 1993 submit a Compliance Plan pursuant to Section F.; and

d. by March 3, 1994 all engines shall be controlled to the limits established by the Board of 

Directors of the Air Pollution Control District.

4. An existing and operating engine that is permanently shut down or electrified after the date of rule 

adoption can be included in determining the percent of total horsepower that meets the requirements 

of Section D.

5. An application for an ATC shall be filed 120 days before the compliance date for each engine set 

forth in I.2.b. and 180 days for engines set forth in I.2.c., I.2.d., and I.3.d.

2. Existing Engines:

a. For any engine subject to an emission limit:

The Rule 333 [date of revised rule adoption] revisions resulted in changes in the oxides of 

nitrogen (NOx) emission limits and the addition of reactive organic compound (ROC) and 

carbon monoxide emission limits as summarized in the attached Tables 1 and 2. 

Any engine previously subject to any emission limit in the April 17, 1997 adopted Rule 333, 

shall continue to comply with the emission limit(s) until such time that compliance with a 

revised emission limit is required. Further, any engine subject to a revised emission limit, as 

indicated in attached Tables 1 or 2, shall comply with the Rule 333 Section E emission limits 

by [two years from the date of revised rule adoption] unless the engine is permanently 

removed. 

Any engine that was previously exempt from Rule 333, but became subject to Rule 333 

emission limits through the [date of revised rule adoption] Rule 202 revisions shall comply 

with the Rule 333 Section E emission limits by [two years from the date of revised rule 

adoption] unless the engine is permanently removed. 

An initial source test demonstrating compliance with a new or revised emission limit shall be 

completed in accordance with Section I prior to [two years from the date of revised rule 

adoption]. The owner or operator of any engine to be modified or replaced to comply with 

the Section E emission limits shall submit an Authority to Construct application to the 

Control Officer by [one year from the date of revised rule adoption].

[Note 109: Existing engines previously complying with the rule’s emission limits are 

required to continue complying with the emission limits until a revised rule limit 

becomes effective. Thus, for Category 1 and 3 engines complying with the emission 

limits, implementation of the revised rule limits is seamless between the old and the 

new rule. 

See Note 

109.

See Note 

110.
STAFF REPORT - Regulation II/Rule 333 Page G-26

June 19, 2008

[Annotated draft of June 19, 2008]

Santa Barbara County APCD Rule 333 333 - 26 April 17, 1997[Date of revised rule adoption]

Category 5 engines previously complying with the NOx limit will need to 1) continue 

to comply with the 797 ppmv NOx at 15 %O2 limit and 2) comply with the revised 

NOx limit and the new ROC and CO limits by two years from the date of the rule 

revision.]

[Note 110: The two-year compliance deadlines for complying with the emission limits 

and for performing source tests are consistent with the deadlines recommended in the 

ARB RACT/BARCT Determination.]

b. For any engine that will be permanently removed from service:

i. by [one month from the date of revised rule adoption], comply with the engine 

identification requirements in Section D.1;

ii. by [six months from the date of revised rule adoption], submit a statement to the 

Control Officer identifying the engine to be removed; and

iii. by [two years from the date of revised rule adoption], remove the engine.

[Note 111: The Section K.2.b provision establishes an alternative compliance method 

to meeting the emission limits and a compliance schedule that are similar to those 

recommended in the ARB RACT/BARCT Determination.]

c. For any engine subject to the exemption in Section B.2 (operating less than 200 hours per 

year):

i. by [one month from the date of revised rule adoption], comply with the engine 

identification requirements in Section D.1 and the recordkeeping provisions in 

Section J.3; and

ii. by [six months from the date of revised rule adoption], install and comply with the 

metering requirements in Sections D.2.

[Note 112: The APCD is establishing deadlines for sources claiming the exemption to 

ensure timely compliance with the requirements. This approach should minimize 

engine owners and operators claiming this exemption only after the APCD has 

identified potential Rule 202 and/or Rule 333 compliance problems with an engine.]

d. For any engine subject to engine identification, plans, or metering requirements in Section 

D:

i. by [one month from the date of revised rule adoption], comply with the engine 

identification requirements in Section D.1 and the recordkeeping provisions in 

Section J;

[Note 113: The majority of the engines have been subject to identification 

requirements implemented either through the APCD permitting process as a permit 

condition, documentation of permit exemptions, and/or through the documentation of 

the APCD emission inventory. Likewise, the recordkeeping provisions should not be 

a new requirement for most engine owners and operators.]
STAFF REPORT - Regulation II/Rule 333 Page G-27

June 19, 2008

[Annotated draft of June 19, 2008]

Santa Barbara County APCD Rule 333 333 - 27 April 17, 1997[Date of revised rule adoption]

ii. by [six months from the date of revised rule adoption]: 

1) submit a new/revised Engine Inspection and Maintenance Plan for the 

Control Officer‟s approval pursuant to Section F. Any previously 

approved Engine Inspection and Maintenance Plan will continue to be in 

force until the Control Officer approves a revised plan; and

2) except as specified in Section B.3, submit a new/revised Compliance Plan 

for the Control Officer‟s approval pursuant to Section G. Previously 

approved Compliance Plans will continue to be in force until the Control 

Officer approves a revised Compliance Plan; and

iii. by [nine months from the date of revised rule adoption], install and comply with 

the metering requirements in Sections D.2 and D.3.

[Note 114: The ARB RACT/BARCT Determination, Section V.B(1) recommends a 

six month deadline for submitting an Emission Control Plan. Also, the 

Determination’s Section VII.A(2) recommends that the Compliance Plan include the 

I&M Plan.]

[Note 115: Compliance with the operating hour metering and the fuel consumption 

metering/quantification requirements is consistent with the ARB RACT/BARCT 

Determination Section VII.B(2) provisions.]

See Note 

114.

See Note 

115.
STAFF REPORT - Regulation II/Rule 333 Page G-28

June 19, 2008

[Annotated draft of June 19, 2008]

Santa Barbara County APCD Rule 333 333 - 28 April 17, 1997[Date of revised rule adoption]

ATTACHMENT

Table 1: Summarized Oxides of Nitrogen Emission Limit Changes

Resulting from the [date of revised rule adoption] Rule 333 Revision

Engine Type Category

Number

April 17, 1997

Adopted Rule 333 

NOx Limits

[Date of Revised 

Rule Adoption]

Adopted Rule 333

NOx Limits Effect of Change

% 

Control

ppmv (at 

15% O2)

% 

Control

ppmv (at 

15% O2)

Rich-Burn NoncyclicallyLoaded Spark Ignition Engines 1 90 50 90 50 No change 

Lean-Burn Spark Ignition 

Engines in the 50 to less than 

100 bhp Range

2 80 125 - 200 Increased emission 

limit

Lean-Burn Spark Ignition 

Engines Rated 100 bhp or 

Greater

3 80 125 80 125 No change

Rich-Burn Cyclically-Loaded 

Spark Ignition Engines 4 90 50 - 300 Increased emission limit

Compression Ignition Engines 

and Dual-Fuel Engines 5 - 797 40 700 Decreased emission limit

Table 2: Summarized Reactive Organic Compound and Carbon Monoxide 

Emission Limit Changes Resulting from the [date of revised rule adoption] Rule 333 Revision

[Note 116: Tables 1 and 2 restate the emission limits from the April 17, 1997 adopted 

Rule 333, Section D, and the proposed revised Rule 333, Section E. For some 

categories (e.g., 1 and 3), there is no change in the emission limits. Other categories 

(e.g., 2 and 4) have emission increases. However, it should be noted that there are no 

Engine Type Category

Number

April 17, 1997 

Adopted Rule 333 

Limits, ppmv (at 

15% O2)

[Date of Revised 

Rule Adoption]

Adopted Rule 333 

Limits, ppmv (at 

15% O2)

Effect of Change

ROC CO ROC CO

Rich-Burn NoncyclicallyLoaded Spark Ignition Engines 1 250 4,500 250 4,500 No change 

Lean-Burn Spark Ignition 

Engines in the 50 to less than 

100 bhp Range

2 750 4,500 750 4,500 No change

Lean-Burn Spark Ignition 

Engines Rated 100 bhp or 

Greater

3 750 4,500 750 4,500 No change

Rich-Burn Cyclically-Loaded 

Spark Ignition Engines 4 250 4,500 250 4,500 No change

Compression Ignition Engines 

and Dual-Fuel Engines 5 - - 750 4,500 New emission limits
STAFF REPORT - Regulation II/Rule 333 Page G-29

June 19, 2008

[Annotated draft of June 19, 2008]

Santa Barbara County APCD Rule 333 333 - 29 April 17, 1997[Date of revised rule adoption]

Category 2 or 4 engines currently subject to the April 17, 1997 adopted emission 

limits. Thus, the APCD does not expect that there will be any increase in emissions 

from the changes to those emission limits. 

Rule 333 Section K.2.a refers to the limits in these tables and requires that:

1. engines previously subject to the April 17, 1997 emission limits continue to 

comply with the emission limits until such time that a revised emission limit is 

required, and

2. engines becoming subject to a new or stricter emission limit comply within 

two years of the adoption of the modified rule.

Tables 1 and 2 are therefore an integral extension of the Section K Compliance 

Schedule provisions.]
THIS PAGE INTENTIONALLY LEFT BLANK
STAFF REPORT - Regulation II/Rule 333 Page H-1

June 19, 2008

Santa Barbara County APCD

Appendix H

Santa Barbara County 

Summarized Data on Emission Reductions, Cost-Effectiveness, and 

Incremental Cost-Effectiveness

Table 1. EMISSION REDUCTIONSa

SOURCE AND EQUIPMENT 

DESCRIPTION

STATIONARY 

SOURCE No.

FACILITY 

No.

DEVICE 

No.

ESTIMATED EMISSION REDUCTIONS (INCREASES)

NOx

(tons/day)

NOx

(tons/year)

ROC

(tons/day)

ROC

(tons/year)

County of Santa Barbara -

Foxen Canyon, two 78 bhp 

compression ignition engines

03706 03706 104269 & 

106429 0.0019 0.7000 (0.0000) (0.0113)

Pacific Operators Offshore, 

Inc., PF Hogan, 440 bhp 

compression ignition engine 

for well drilling 

08001 08001 007107 0.0057 2.0821 (0.0000) (0.0040)

Pacific Operators Offshore, 

Inc., PF Houchin, 440 bhp 

compression ignition engine 

for well drilling 

08001 08002 007108 0.0040 1.4542 (0.0000) (0.0028)

Purisima Hills LLC - Barham 

Ranch, H.P. Boyne Lease, six 

65 bhp uncontrolled spark 

ignition engines

01153 03777

005908, 

005909, 

005910, 

005911, 

005912, &

009015

0.0062 2.2742 (0.0018) (0.0168)

TOTALS 0.0178 6.5105 (0.0001) (0.0349)

 

a Based on engines in the 2005 Emission Inventory.
STAFF REPORT - Regulation II/Rule 333 Page H-2

June 19, 2008

Santa Barbara County APCD

THIS PAGE INTENTIONALLY LEFT BLANK
STAFF REPORT - Regulation II/Rule 333 Page H-3

June 19, 2008

Santa Barbara County APCD

Table 2. COST-EFFECTIVENESSa

SOURCE TYPE 

ENGINE

RATING 

(Bhp)

UNCONTROLLED 

NOx EMISSIONS 

(tons/year)

PROPOSED 

NOx LIMIT 

(ppmv @ 15% 

O2)

NOx 

EMISSIONS 

REDUCED 

(tons over a 

ten-year 

period)

INITIAL 

TUNING 

COSTS 

($)

NPV OF 

INCREASED 

ANNUAL 

OPERATING 

AND MAINT. 

COSTS ($)

INITIAL 

TUNING COSTS 

PLUS NPV OF 

THE ANNUAL 

O & M COSTS 

($)

COSTEFFECTIVENES

S ($/ton)

County of Santa Barbara -

Foxen Canyon (SSID 03706, 

DID 104269)

CI 78 8.99 700 27.37 2000 40,437 42,437 1,550

County of Santa Barbara -

Foxen Canyon (SSID 03706, 

DID 106429)

CI 78 1.21 700 3.68 2000 40,437 42,437 11,532

Pacific Operators Offshore, 

LLC, Platform Hogan (SSID 

8001, DID 007107)

CI 400 4.81 700 10.95 2000 57,609 59,609 5,444

Pacific Operators Offshore, 

LLC, Platform Houchin 

(SSID 8001, DID 007108)

CI 400 3.36 700 7.65 2000 57,609 59,609 7,795

Purisima Hills LLC (SSID 

01153, DID No. 005908, 

005909, 005910, 005911, 

005912, & 009015)

SI 65 1.13 300 3.79 2000 38,646 40,646 10,724

 

a Based on engines in the 2005 Emission Inventory.
STAFF REPORT - Regulation II/Rule 333 Page H-4

June 19, 2008

Santa Barbara County APCD

Table 3. INCREMENTAL COST-EFFECTIVENESSa

SOURCE TYPE 

ENGINE

RATING 

(Bhp)

INITIAL 

TUNING 

COSTS 

($)

LOW EMISSION 

TUNING NPV ($)

LOW EMISSION 

TUNING NOx TOTAL 

EMISSION 

REDUCTIONS (tons)

LOW EMISSION 

TUNING METHOD 

COST-EFFECTIVENESS 

($/ton)

ELECTRIFICATION 

NPV ($)

ELECTRIFICATION 

NOx TOTAL EMISSION 

REDUCTIONS (tons)

ELECTRIFICATION 

METHOD COST- EFFECTIVENESS ($/ton)

INCREMENTAL 

COSTEFFECTIVENESS 

($/ton)

Purisima Hills LLC (SSID 

01153, DID No. 005908, 

005909, 005910, 005911, 

005912, & 009015)

SI 65 2000 40,646 3.79 10,724 44,270 11.35 3,900 479

 

a Based on engines in the 2005 Emission Inventory.
STAFF REPORT - Regulation II/Rule 333 Page I-1

June 19, 2008

Santa Barbara County APCD

Appendix I

Santa Barbara County 

Identification of Existing Federal and APCD Regulations 

that Apply to the Same Equipment or Source Type Covered in Rule 333

This section is included to comply with the California Health & Safety Code Section 40727.2 

requirements. 

FEDERAL AIR POLLUTION CONTROL REQUIREMENTS

There are several federal air pollution control requirements that apply to the same equipment or 

source types covered by Rule 333. In general, engines subject to Rule 333 may be subject to one 

or more of the following federal requirements.

1. 40CFR60, Standards of Performance for New Stationary Sources, Subpart IIII, Standards 

of Performance for Stationary Compression Ignition Internal Combustion Engines

2. 40CFR60, Standards of Performance for New Stationary Sources, Subpart JJJJ, Standards 

of Performance for Stationary Spark-Ignition Internal Combustion Engines 

3. 40CFR63, National Emission Standards for Hazardous Air Pollutants for Source 

Categories, Subpart ZZZZ, National Emission Standards for Hazardous Air Pollutants for 

Stationary Reciprocating Internal Combustion Engines

4. 40CFR89, Control of Emissions from New and In-Use Nonroad Compression-Ignition 

Enginesa

5. 40CFR91, Control of Emissions from Marine Spark-Ignition Engines

6. 40CFR94, Control of Air Pollution from Marine Compression-Ignition Engines

7. 40CFR1048, Control of Emissions from New, Large Nonroad Spark-Ignition Engines

________________________

SANTA BARBARA COUNTY AIR POLLUTION CONTROL DISTRICT REQUIREMENTS

Table 1 shows the rules that apply to internal combustion engines.

Table 1. RULES THAT APPLY TO INTERNAL COMBUSTION ENGINES

GENERIC REQUIREMENTS AFFECTED EMISSION 

UNITS BASIS FOR APPLICABILITY

RULE 201: Permits Required All emission units Emission of pollutants

RULE 202: Exemptions to Rule 201 Applicable emission units Insignificant activities/emissions, 

per size/rating/function

RULE 210: Fees All emission units Administrative 

RULE 212: Emission Statements All emission units Administrative

RULE 302: Visible Emissions All emission units Particulate matter emissions

 

a Compression ignition emergency standby engines are not subject to Rule 333.
STAFF REPORT - Regulation II/Rule 333 Page I-2

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Santa Barbara County APCD

GENERIC REQUIREMENTS AFFECTED EMISSION 

UNITS BASIS FOR APPLICABILITY

RULE 303: Nuisance All emission units Emissions that can injure, 

damage or offend.

RULE 304: PM Concentration –

North Zone

Each PM source Emission of PM in effluent gas

RULE 305: PM Concentration –

South Zone

Each PM source Emission of PM in effluent gas

RULE 309: Specific Contaminants All emission units Combustion contaminants 

RULE 310: Odorous Org. Sulfides All emission units Emission of organic sulfides

RULE 311: Sulfur Content of Fuel All combustion units Use of fuel containing sulfur

RULE 333: Control of Emissions 

from Reciprocating IC Engines. Internal combustion engines Engines rated at 50 brake 

horsepower and greater

REGULATION VIII: New Source 

Review

All emission units Addition of new equipment or 

modification to existing 

equipment. Applications to 

generate ERC Certificates.

REGULATION XIII (RULES 1301-

1305): Part 70 Operating Permits

All emission units A stationary source is a major 

source.

A review of Table 1 indicates that there are no overlapping or conflicting averaging provisions, 

units, or any other pertinent provisions associated with emission limits. 
Note: Attachment J, Public Comments and the APCD Responses, is omitted from this Staff Report to reduce 

redundancy. Attachment 6 of the SIP submittal package includes the Public Comments.
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Santa Barbara County APCD

Appendix K

Santa Barbara County 

Comparison of the Proposed Amended Rules to the Rules in the Adjoining Air Districts

The Air Pollution Control Districts that border the Santa Barbara County APCD (SBC) include the San Joaquin 

Valley Unified APCD (SJV), the San Luis Obispo County APCD (SLO), and the Ventura County APCD (VC). For 

performing the comparisons of the proposed revised rules, rulemaking staff considered the following categories: 

1. Definitions, 

2. Authority to Construct Requirement, 

3. Exemptions and General Provisions for Permit Exemptions, and 

4. Internal combustion engine prohibitory rule requirements.

The following provides summaries of the comparison findings for each of these categories.

DEFINITIONS (SBC RULE 102)

In general, the SJV, SLO, and VC engine rules include definitions that are similar to the ones we are proposing for 

Rule 102. However, the Santa Barbara County Air Pollution Control District prefers to locate the definitions in the 

general definition rule (Rule 102) instead of Rule 333. Thus, our approach to the location of the definitions differs 

from the adjoining air districts. Their general definition rules do not contain the terms being proposed for addition to 

our general definition rule. The APCD is proposing that the new definitions be added to Rule 102 because the terms 

are used in more than one rule. Where a definition is applicable to only one rule, the SBC places the definition in 

that rule only. Generally, the definitions being added to Rule 102 are needed to clarify terms that are used in Rule 

202 (Exemptions to Rule 201) and Rule 333 (Control of Emissions from Reciprocating Internal Combustion 

Engines). 

AUTHORITY TO CONSTRUCT (ATC) REQUIREMENTS (SBC RULE 201.D)

The changes to SBC Rule 201.D include:

1. clarifying the ATC required provision by including the “using” and “use” terms, and 

2.removing the potential ATC/PTO requirement for the use of pile drivers, dredges, pipe-laying, and derrick barges 

(Section 201.D.2) and adding exemption language to Rule 202.

Regarding the above item 1, the SBC is the first air district to add the “using” and “use” terms. We are adding these 

terms for consistency with the Health and Safety Code and to allow for clearer exemptions. On item 2 above, the 

adjoining air districts do not exempt pile drivers, dredges, pipe-laying, and derrick barges. 

PERMIT EXEMPTIONS (SBC RULE 202)

These are in several categories.

 Exceptions to Permit Exemptions. Currently, SBC has one exception to the permit exemptions. It 

indicates any equipment, activity, or operations proposed by an application to be subject to an Emission 

Reduction Credit is not exempt. 

SJV and SLO have several exceptions to their permit exemptions. Their exceptions range from negating the 

exemption for an emission unit subject to New Source Performance Standards to negating an exemption 

where the owner of an otherwise exempt emission unit specifically requests a permit to operate. VC does 

not have any exceptions to its exemption rule.
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Santa Barbara County APCD

 Temporary Equipment Exemption. SBC Rule 202.D.5 exempts temporary equipment provided certain 

conditions are met (e.g., emissions are 1 ton per year or less). SJV, SLO, and VC do not have an exemption 

provision for temporary equipment. 

 Exemption for Stationary Sources that have Uncontrolled Actual Emissions less than 1 Ton per Year. 

This is an existing permit exemption in SBC Rule 202. SJV, SLO, and VC do not have a stationary source 

exemption provision. 

 General Provision to Accumulate Ratings When Several Equipment Units are Used in the Same 

Process. The SBC permit exemption rule does not currently include a provision on accumulating the 

ratings of equipment used in the same process for determining exemption applicability. The SJV and VC 

rules do not have such a provision either. However, the SLO Rule 201 Sections B.1 and B.2 include such a 

provision. SBC staff proposes a new provision that is similar to the SLO provision for SBC Rule 202, 

general provision D.15 and reflects our long-standing implementation.

 General Provision to Require Emission Offsets for Equipment Used in Construction Activities. This 

provision, currently found in SBC Rule 202.F.3, requires emission offsets if the combined emissions from 

all construction equipment used to construct a stationary source that requires an Authority to Construct or 

Permit to Operate exceed 25 tons of any pollutant (CO not included) in a 12 month period. The APCD 

proposes relocating the provision into the general provisions of Rule 202 (new Section D.16).

None of the adjoining air districts have a similar general provision to require offsets if emissions from 

construction equipment used to construct a stationary source requiring an Authority to Construct or Permit 

to Operate exceeds 25 tons per 12 month period. 

 General Provision on not Allowing Derated Equipment to be Exempt. SBC staff propose adding 

provisions to Rule 202 specifying that no compression/spark ignition engine, gas turbine engine or 

combustion equipment otherwise subject to permit shall be exempt because it has been derated. The basis 

for this approach is that permitting derated equipment provides a method to ensure that the derating is 

enforceable and permanent.

SJV and VC rules do not have provisions that address equipment derating. SLO Rule 4701, Section 3.6, 

infers that derated engines are required to be permitted. 

 Single-Engine Exemption Cut Off Rating. The SBC Rule 202 exemption cut-off on a single engine basis 

is currently 100 brake horsepower. The EPA recommends that this cut off be less than 50 brake 

horsepower. Also, the state Airborne Toxic Control Measure for Portable Compression Ignition Engines 

applies to engines rated at 50 brake horsepower and greater. Therefore, for consistency with the ATCM, 

the APCD proposes that the permit requirements also apply to engines rated 50 brake horsepower or 

greater. (The multiple small spark ignition engine exemption/permitting provision - see next bulleted item -

supersedes the single-engine exemption provision for sources with multiple spark ignition engines.) 

SJV exempts engines with horsepower ratings of 50 or less. VC and SLO rules exempt engines rated less 

than 50 brake horsepower. 

 Stationary Sources with Multiple Small (Greater Than 20 to Less Than 50 Brake Horsepower) Spark 

Ignition Engine Exemption/Permitting Provision. Currently, the SBC Rule 202 exempts spark ignition 

engines in the 20 to 100 brake horsepower range, if the aggregate rating of all such engines at a stationary 

source is 500 brake horsepower or less. Conversely, if the aggregate of such engines exceeds 500 brake 

horsepower, permits are required. 

Under the proposed revised Rule 202 provision, if spark ignition engines in the greater than 20 to less than 

50 brake horsepower range have an aggregate rating less than 400 brake horsepower (approximately an 

uncontrolled potential to emit less than 40 tons of NOx per year) at a stationary source, the engines are 
STAFF REPORT - Regulation II/Rule 333 Page K-3

June 19, 2008

Santa Barbara County APCD

exempt. Conversely, under the proposed revised rule, if the engines in this range have an aggregate rating 

of 400 brake horsepower or greater, then permits are necessary.

SJV, SLO, and VC do not have an exemption or permitting provision for multiple small 

spark ignition engines at a stationary source. 

 Exemption for Gas Turbine Engines. The existing SBC Rule 202, Section F.1.f provision indicates gas 

turbines with a maximum heat input rate of 3 million British thermal units per hour or less are exempt. Staff 

plan to maintain this threshold and allow limited same-process additions of natural gas-fired microturbines 

that have been certified by the ARB, provided the potential annual emissions of each affected pollutant does 

not exceed 1 ton (except carbon monoxide, which shall not exceed 5 tons).

SJV has a specific exemption for gas turbines that have a maximum heat input rating of 3.0 million British 

thermal units per hour or less and a general provision to exempt low emitting units. Low emitting units are 

emission units that have an uncontrolled emission rate of any single contaminant that is less than or equal to 

2 pounds per day or, if greater than 2 pounds per day, less than or equal to 75 pounds per year. 

SLO exempts gas turbines rated 3.0 million British thermal units per hour or less. VC exempts gas turbines 

that have a rated full load output of less than 0.30 megawatts (300 kilowatts). 

 Exemption for Engines Rated at Less than 50 Brake Horsepower Used in Military Tactical Support 

Operations and Other Miscellaneous Operations. This is an existing provision in SBC Rule 202. 

Unlike SBC, SJV, SLO, and VC exempt all engines rated less than 50 brake horsepower, regardless of the 

use of multiple small engines at a stationary source. Hence, the adjoining air districts do not have a need 

for an exemption for small engines (less than 50 brake horsepower) used in military tactical support 

operations and other miscellaneous operations.

 Exemption for Engines Used in Conjunction with Offshore Drilling Equipment. The current SBC 

provision exempts offshore drilling equipment, provided the emissions from such equipment are less than 

25 tons per stationary source of any affected pollutant during any 12 month period. The APCD proposes to 

delete this exemption.

Due to its geographical location, SJV does not regulate an area that could potentially have offshore drilling. 

SLO and VC do not have exemptions for offshore drilling equipment. 

 Exemption for Specialty Equipment. The SBC is proposing to add a new “specialty equipment” 

exemption for limited emergency situations located in the Outer Continental Shelf or State Territorial 

Waters. SJV does not regulate activities in the OCS or STW. SLO and VC do not have exemptions for the 

use of specialty equipment in the OCS or STW.

 General Permitting Provisions or Exemption for Equipment Used in Dredging, Pile Driving, PipeLaying Barges and Derrick Barges. Currently SBC Rule 201.D.2 includes a provision that such 

equipment will require a permit if the potential to emit is 25 tons per any 12 month period or greater. 

Conversely, the equipment is exempt if the potential emissions are less than 25 tons per any 12 month 

period. The SBCAPCD proposes to modify and move the Rule 201.D.2 provisions to Rule 202.F.7. The 

provision is being expanded to include cable-laying vessels/barges. However, the exemption for dredges is 

being eliminated as these units are considered erected and subject to Rule 201.D.1.

SJV Rule 2020, Section 4.4, and SLO Rule 201, Section C.2 indicate, “Locomotives, airplanes, and 

watercraft used to transport passengers or freight. This exemption is not intended to apply to equipment 

used for the dredging of waterways or to equipment used in pile driving adjacent to or in waterways.” In 

addition to exempting locomotives, aircraft, and recreational watercraft, VC Rule 23.D.2 exempts marine 

vessels. (But not equipment mounted on them that would otherwise require a permit.) 
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Santa Barbara County APCD

To summarize this permitting/exemption category comparison, the SJV, SLO, and VC rules do not exempt 

equipment used in pile driving, or cable and pipe-laying vessels/barges or derrick barges, regardless of the 

equipment‟s potential to emit. However, the SBC will provide exemptions for such equipment, provided 

certain requirements are met. 

 Marine Vessel Engine Exemptions from New Source Review. The APCD is proposing this exemption 

(Rule 202.F.8) to address concerns stemming from the deletion of the construction engine exemption. None 

of the adjoining air districts have a similar exemption.

 Provision on a General Category Exemption not Applying to any Component which Otherwise 

Requires a Permit. The general provision of SBC Rule 202.D.11 disallows exemptions in cases where 

individual components are permitted. The current SBC Rule 202.G.2 provision needs to be revised for 

improved clarity in light of the Rule 202.D.11 provision.

SJV and VC exemption rules do not have this provision. The SLO Rule 201.A.2 indicates, “An otherwise 

exempt piece of equipment requires a permit if it is part of a process that requires a permit.”

 Exempting Powder Coating Operations. The existing SBC Rule 202.I.5 exempts only polyurethane 

powder coating operations. Staff proposes expanding this exemption to include all powder coating 

operations, provided the ROC content of the powder coatings does not exceed five percent, by weight.

The SJV Rule 2020, §6.8.3 exempts powder coating operations that use less than five pounds of coating 

material per day or less than fifty pounds of coating material per year. SLO staff exempt powder coating 

operations by their two pounds per day exemption. VC staff exempts powder coating operations via their 

Rule 23.F.11.b (use of coating materials less than 200 pounds per 12 month rolling period).

 Exemptions for Wineries, Breweries, Distilleries and Similar Facilities. The adjoining air districts do 

not have a specific exemption for these facilities. 

 Exemption for Portable Water Heaters Used for Underwater Diving Activities. None of the adjoining 

air districts have a specific exemption for these boilers. 

 Airborne Laser Program Exemption from New Source Review. This new exemption (Rule 202.P.14) is 

a limited provision being proposed in response to a request by Vandenberg Air Force Base. Thus, LSO, 

SJV, and VC rules do not have a similar exemption.

 Exemption for Solvent Wipe Cleaning Operations. The SBC is proposing changes to the existing 

solvent wipe cleaning exemption. Sources using 55 gallons per year or less are exempt from the SBC 

permitting requirement. The SJV Rule 2020, Section 6.9.3, and the SLO Rule 201, Section J.2.c, provide 

an exemption for solvent cleaning operations using less than 25 gallons of solvent per year (with a monthly 

recordkeeping requirement). The VC Rule 23.10.d provides an exemption for solvent cleaning operations 

having emissions less than 200 pounds per rolling 12-month period per source. The VC 200 pound limit is 

for each ROC, methylene chloride, 1,1,1 trichloroethane, and perchloroethylene. Also, the exemption does 

not apply for coating, graphic arts, adhesive/sealant and polyester resin operations.

In summary:

1. The maximum allowable solvent usage under the SJV and SLO exemptions is about fifty percent less 

than the SBC limit. 

2. The VC exemption is based on meeting an emissions rate criteria on a per ROC (and a limited per 

hazardous air pollutant) basis. The exemption excludes certain processes from the exemption. 
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June 19, 2008

Santa Barbara County APCD

ENGINE PROHIBITORY RULE REQUIREMENTS (SBC RULE 333)

The SBC and SLO engine rule provisions can be regarded as “reasonably available control technology” 

requirements, whereas SJV and VC rules are stricter and are considered “best available retrofit control technology.” 

This results in the SJV and VC engine emission limits being lower (stricter) than the SBC and SLO rules.

The engine prohibitory rule requirements have several components, as outlined below.

 Applicability. SBC staff proposes to make the engine prohibitory rule applicability similar to SLO and 

VC: the requirements apply to engines rated at 50 brake horsepower and greater. The SJV engine rules 

apply to engines rated greater than 50 brake horsepower.

 Exemptions. As is the case for general permit exemptions, the adjoining air districts have a wide range of 

exemptions in their engine rules. For the engine prohibitory rule exemptions, there are two types of 

exemptions: 

a) Total Exemption: Engines are exempt from the prohibitory rule in its entirety, and 

b) Partial Exemption: Engines are partially exemption from the prohibitory rule requirements (e.g., exempt 

from the emission limits, but not from the recordkeeping provisions). 

The following summarizes comparisons of the different SBC Rule 333 exemptions.

1. Engines Burning Landfill Gas (SBC Partial Exemption). A source claiming this exemption in Santa 

Barbara County needs to maintain fuel monitoring information and other documentation to support the 

claim of exemption. SJV, SLO, and VC engine rules do not exempt engines burning landfill gas.

2. Engines Exempt from Permit (SBC Total Exemption). SJV engine Rule 4701 (Phase 1) infers 

engines exempt from permit are exempt from the prohibitory rule in the rule‟s applicability provision. 

The SJV engine Rule 4702 (Phase 2) and the SLO and VC engine rules do not have this exemption.

3. Engines Derated to Less Than 50 Brake Horsepower (SBC Rule 333 Total Exemption). For 

derated engines, the SJV Rule 4701 provides a partial exemption and the SJV Rule 4702 provides a 

total exemption. The SLO and VC rules do not have any exemptions for derated engines.

4. Compression Ignition Emergency Standby Engines (SBC Total Rule 333 Exemption). Except for 

administrative provisions necessary to substantiate the exemption, SJV and SLO rules exempt 

emergency engines. VC exempts emergency standby engines, provided their maintenance operations 

do not exceed 50 hours per calendar year. Exempting spark ignition emergency standby engines from 

the prohibitory rule is consistent with the ARB RACT/BARCT Determination. Also, compression 

ignition emergency standby engines are subject to the state ATCM. By exempting these engines from 

Rule 333 in its entirety, the APCD is eliminating the engine owner and operator‟s Rule 333 compliance 

burden.

5. Engines that Operate Less than 200 Hours per Year (SBC Partial Exemption). All of the 

adjoining air districts have this exemption; the VC rule exempts these engines from their entire engine 

rule.

6. Compression Ignition ARB or EPA Tiered Engines (SBC Partial Exemption). None of the 

adjoining air districts have the provision proposed in new Section 333.B.3. This section will provide a 

partial exemption for ARB- or EPA-tiered diesel-fueled engines. Assuming the routine monitoring 

checks with a portable analyzer do not exceed 560 parts per million of NOx at 15% oxygen, these 

engines will not need to submit a compliance plan. Further, they will not be subject to initial and 
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Santa Barbara County APCD

biennial source testing provisions.

 Definitions. Generally, the definitions are the same between the air districts. SBC is recommending the 

relocation of some of the definitions currently found within the prohibitory rule be moved into the general 

definition rule (102). The recommendation is made only for those terms that appear in more than one SBC 

rule.

 Requirements. There are several components to the engine rule requirements, as shown in the following 

summaries.

1. Engine Identification. Historically, identification of permitted engines has been required through a 

permit condition. Except for SLO, none of the adjoining air districts has the requirement that the 

owner or operator identify the engines. SLO incorporates the engine identification requirement within 

the Engine Operator Inspection Plan.

2. Elapsed Operating Time Meters and Fuel Meters. SBC Rule 333 currently requires elapsed 

operating time meters. Also, fuel meters are required for engine fired on landfill gas and engines 

subject to source testing. SBC staff proposes that all engines subject to Rule 333 be equipped with fuel 

meters. This requirement is consistent with the ARB RACT/BARCT Determination. 

SJV requires engines to be equipped with these meters, but SLO and VC do not. 

3. Continuous Monitoring Systems. For qualifying new engines (rated ≥ 1,000 bhp, with > 2,000 hours 

per year allowable operating schedule), the amended Rule 333 will require the use of a continuous 

emissions monitoring system. The SJV rule and the ARB RACT/BARCT Determination require a 

continuous monitoring system, which may be a continuous emissions monitoring system (CEMS), a 

parametric emissions monitoring system (PEMS), or an alternative monitoring system approved by the 

APCO. Unlike the proposed SBC requirement (which applies only to new engines), the SJV and ARB 

RACT/BARCT Determination provisions apply to existing and new engines. SLO and VC rules do not 

include a requirement for and continuous monitoring system.

4. Emission Limits. All adjoining air district engine rules have emission limits that vary due to the level 

of control (RACT vs. BARCT) as described earlier. SBC proposes to use the diesel engine RACT 

limit from San Diego and the limits from the ARB RACT/BARCT Determination for the spark ignition 

engines. 

5. Alternative Emission Control Plans. The SBC engine rule currently has an outdated Alternative 

Emission Control Plan (AECP) provision. SBC staff recommends that the existing AECP be deleted as 

the deadline for submitting such plan has passed and the APCD did not receive any plans.

SJV includes an AECP provision, but SLO and VC do not. 

6. Limiting use of Anhydrous Ammonia to Meet Emission Limits. The SBC Rule 333 currently 

prohibitions the use of anhydrous ammonia. At the request of the regulated community, this 

prohibition is being modified to allow its use provided certain safety and potential environmental 

impact issues are addressed. None of the adjoining air districts have a prohibition on the use of 

anhydrous ammonia. (The SLO and VC rules limit the amount of ammonia from an emission control 

system to 20 parts per million by volume. Neither the SBC or the SJV engine rules have such a limit.)

7. Engine Inspection and Maintenance Plans. The existing and proposed revised SBC engine rule 

includes an engine Inspection and Maintenance Plan. Also, all adjoining air districts require such 

plans. 

VC and SLO requirements indicate inspections shall be conducted every quarter or after every 2,000 
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June 19, 2008

Santa Barbara County APCD

hours of engine operation; and, in no event, shall the frequency of inspection be less than once per year. 

SJV Rule 4701 (Phase 1) and portions of the SJV Rule 4702 (Phase 2) require quarterly inspections.a 

However, the SJV Rule 4702 (Phase 2) requires monthly inspections for prime engines operating in 

excess of 200 hours per year and other engines not subject to the quarterly inspection frequency.

None of the adjoining air district rules have a provision that an excessive portable analyzer instrument 

reading will not be a violation if corrective action is taken within 15 days of finding. This is a 

provision in the current and the proposed modified Rule 333.

8. Compliance Plans. The existing and proposed revised SBC engine rule includes a requirement for 

Compliance Plans. The SJV engine rule has a section on Emission Control Plans that requires the 

owner to inform the Control Officer of the actions to be taken to satisfy the emission requirements of 

the rule. The SJV provision on Emission Control Plans is essentially the same as the SBC provisions 

on Compliance Plans.

The SLO and VC Engine Operator Inspection Plan provisions include a requirement for identification 

of the type of NOx control system to be used for compliance. Other than these requirements for 

identification, SLO, and VC do not have specific requirements for a Compliance Plan or an Emission 

Control Plan.

9. Source Testing. The existing and proposed revised SBC engine rule includes requirements for testing. 

All of the adjoining air districts have a requirement for conducting source tests, with specificity on the 

source test methods. The source testing frequency ranges from annually to every 8,760 hours of 

operation or 3 years, whichever occurs first. The ARB RACT/BARCT Determination specifies a 

source testing frequency of at least once every 24 months. The SBC biennial source testing frequency 

is consistent with the ARB-recommended testing frequency.

10. Recordkeeping. SJV, SLO, SBC, and VC engine rules have recordkeeping provisions on engine 

operating logs, inspection and maintenance, and CEMS data. SBC also includes recordkeeping 

provisions for engines subject to the less than 200 hours per year exemption and Engine Heat Input 

Verification Plans.

11. Compliance Schedule. The existing and proposed modified SBC Rule 333 includes a provision on 

compliance schedules. The proposed amended SBC Rule 333 compliance schedule is complicated 

somewhat by the fact that some engine categories have new and stricter requirements being phased in 

by the same rule. All of the adjoining air district engine rules include a compliance schedule. SJV has 

taken the approach of issuing separate rules for phased approaches when implementing new emission 

limits (e.g., Rule 4701 and Rule 4702).

12. Reporting. The existing and proposed modified SBC Rule 333 do not require annual reporting. 

Likewise, the SJV engine rules do not have annual reporting provisions. However, the SLO and VC 

engine rules require annual reports. 

 

a

SJV Rule 4702 (Phase 2) allows quarterly engine inspections for engines that are used for emergency purposes that 

have no more than 200 hours per year of maintenance operations and engines that operate no more than 200 hours 

per year.
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Appendix L

Santa Barbara County 

Impacts of the Revised Rules to Industry and the APCD

Industry Impacts 

The revised engine exemptions and rules will cause varying degrees of impacts depending on the engine size, engine 

type, and its operating schedule. Sources with permitted engines rated at less than 50 brake horsepower are not 

subject to Rule 333 and will experience fewer impacts than sources with engines needing to comply with Rule 333. 

The following provides information on the impacts from the various rule revisions and the sources potentially 

impacted by the changes.

RULE 102, DEFINITIONS

The APCD is unaware of any source that will be impacted by the addition of the new definitions.

RULE 201, PERMITS REQUIRED

Impacts from the Rule 201.D changes are interrelated with the deletion of the Rule 202 construction engine 

exemption and the new Rule 202 exemptions for 1) pile drivers, cable-laying and derrick barges and their 

associated marine vessels, and 2) specialty equipment. There are no known sources that will be specifically 

impacted by the proposed revisions to Rule 201.

RULE 202, EXEMPTIONS TO RULE 201

In general, the APCD is unaware of specific sources that will be impacted by the numerous minor and 

administrative-type Rule 202 changes. Some of the new exemptions were added in response to requests by the 

regulated community. Thus, these are expected to provide beneficial impacts to industry. 

The removal of the construction exemption will require construction engine owners to either register in the 

statewide portable equipment registration program or obtain an APCD Permit to Operate. Due to construction 

engines being currently exempt from permitting, the APCD has no data available to determine which owners 

will be impacted by this change.

Other exemption changes that will cause engine permitting impacts include the revisions to the spark ignition 

engine exemption and the repeal of the offshore well drilling exemptions. The following provides information 

on the impacts from those changes. 

Some sources will be affected by the 202.F.1.f general spark ignition engine exemption threshold revisions and 

the 202.F.6 offshore drilling equipment exemption deletion. The APCD does not know the exact number or 

location of the engines that will require permits as a result of the rule revision because of the current “permit 

exempt” status for these engines. Under the proposed amendments, there will be several sections in Rule 202.F 

that will make currently exempt engines subject to permitting. As shown in Appendix B, 89 engines in the 

following categories will become subject to permitting due to the various Rule 202 changes:

1. 16 spark ignition engines in the 50 to 100 brake horsepower range (reference Rule 202.F.1.f).

2. 26 spark ignition engines in the greater than 20 to less than 50 brake horsepower range where the aggregate 

rating is 400 bhp (reference Rule 202.F.1.f).

3. 40 spark ignition engines that have been derated (reference Rule 202.F.1.f).a

 

a The removal or modification of an engine derating mechanism will constitute a modification requiring APCD 

approval in the form of an Authority to Construct. Such a proposal will be subject to Regulation VIII, New Source 

Review.
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June 19, 2008

4. 7 well drilling engines (reference deleted Rule 202.F.6). 

Based on our 2005 inventory (and as detailed in Appendix B), 9 companies (all associated with oil and gas 

production or processing) will need to obtain permits for 89 engines due to changes to Rule 202.F. 

Table 1 summarizes the anticipated fee impacts due to the initial permitting, equipment modifications, and the 

initial source testing of the engines becoming subject to Rule 333 limits for the first time.a The fee impact from 

the initial permitting of the 89 engines that lose their exemption is $51,118.b The total fee for the ten engines to 

be modified to comply with Rule 333 emission limits is $6,4589c One facility, Venoco‟s Platform Holly, has 

three well drilling engines that are already controlled, but will require a source test. The fee associated with the

testing of those engines is estimated to be $2,237. Three other sources have engines that will require source 

testing: 

1. Pacific Operators Offshore, Inc. (SSID 08801) – fee to be assessed on the cost reimbursement basis.

2. Purisima Hills LLC – Barham Ranch, H.P. Boyne Lease (SSID 01153) – the total fee for the source testing 

of the six engines is $3,404.

3. SBC Resource Recovery and Waste Mgmt Div., County of Santa Barbara – Foxen Canyon (SSID 03706) –

the total fee for the source testing of the two engines is $1,849.

There are nine currently permitted engines rated less than 50 brake horsepower that will no longer be subject to 

permitting under the proposed amended Rule 202.F.1.f exemption. Table 2 (on page L-5) lists the engines and 

indicates there will be an overall reduction of $1,771 in triennial reevaluation fees for the two sources.

Table 3 (on page L-7) provides a summary of the estimated company compliance cost impacts associated with 

engines needing to comply with the emission limits for the first time or needing to comply with the revised 

emission limits. These costs are in addition to the source testing, permitting, and/or permit modification fees 

shown in Table 1.

 

a

Sources will have additional ongoing fee impacts (e.g., increased annual fees, reevaluation fees for engines that 

become subject to permitting, and recurring source test fees if subject to the emission limits).

b

Includes the application filing fee and the PTO fee as shown in Table 1. Some sources have their fees assessed on 

a cost reimbursement basis for which there is no present estimate.

c

Includes the ATC and PTO filing fees, the ATC modification fee, and the PTO modification fee as shown in Table 

1. The three sources anticipated to have the ten engines requiring modification are shown in Appendix H and 

include: 1) County of Santa Barbara – Foxen Canyon (SSID 3706), 2) Pacific Operators Offshore, Inc. – Platforms 

Hogan and Houchin (SSID 8001), and Purisima Hills – Barham Ranch, H.P. Boyne Lease (SSID 01153). Some 

sources have their fees assessed on a cost reimbursement basis for which there is no present estimate.
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Santa Barbara County APCD

Table 1. SUMMARY OF THE ANTICIPATED FEE IMPACTS DUE TO INITIAL ENGINE PERMITTING, 

PERMITS FOR ENGINE MODIFICATIONS, AND THE INITIAL ENGINE SOURCE TESTSa

Col.1 Col.2 Col.3 Col.4 Col.5 Col.6 Col.7 Col.8 Col.9 Col.10 Col.11 Col.12

Company Description and 

Stationary Source Description

Stationary 

Source No.

Initial App'n 

Fee

Initial PTO 

Fee

Increased 

Annual 

Emission FeeIncreased Air 

Toxic Program 

Fee

Increased 

AQAP Fee

App'n Fee for 

ATC Mod'nATC Mod'n 

Fee

Source Test 

Fee

App'n Fee for 

PTO Mod'nPTO Mod'n 

Fee

Source's 

Overall 

Fee 

Impacts

B.E. Conway Energy, Inc., 

Conway Oil, Inc. -

Magenheimer

01944 $325 $219 $0 $0 $0 - - - - - $544

Catco Energy 01510 $325 $1,900 $3,657 $286 $1,553 - - - - - $7,721

Elysium Russell, LLC., 

Elysium Russell, LLC. 04639 $325 $2,115 $5,353 $326 $2,403 - - - - - $10,522

ExxonMobil Production 

Company, Exxon - SYU 

Project

01482 $325 Reimb. $448 $0 $900 - - - - - $1,673

Greka Oil & Gas, Inc., Clark 

Avenue Source 02200 $325 $1,967 $111 $8 $607 - - - - - $3,018

Greka Oil & Gas, Inc., 

Continental 05032 $325 $286 $0 $0 $0 - - - - - $611

Greka Oil & Gas, Inc., Gato 

Ridge 02680 $325 $1,415 $92 $10 $40 - - - - - $1,882

Greka Oil & Gas, Inc., Los 

Flores 08678 $325 $1,955 $0 $0 $0 - - - - - $2,280

Greka Oil & Gas, Inc., SMV 

East 08675 $325 $1,543 $1,169 $0 $517 - - - - - $3,555

Greka Oil & Gas, Inc., Zaca 

Field 08702 $325 $669 $698 $77 $311 - - - - - $2,079

Pacific Operators Offshore, 

LLC., Pacific Operators -

Carpinteria

08001 $325 Reimb. $1,606 $0 $1,120 $325 Reimb. Reimb. $325 Reimb. $3,700

 

a Based on the 2005 Emission Inventory. Data for sources with multiple engines is summarized and shown in a single row.
STAFF REPORT - Regulation II/Rule 333 Page L-4

June 19, 2008

Santa Barbara County APCD

Col.1 Col.2 Col.3 Col.4 Col.5 Col.6 Col.7 Col.8 Col.9 Col.10 Col.11 Col.12

Company Description and 

Stationary Source Description

Stationary 

Source No.

Initial App'n 

Fee

Initial PTO 

Fee

Increased 

Annual 

Emission FeeIncreased Air 

Toxic Program 

Fee

Increased 

AQAP Fee

App'n Fee for 

ATC Mod'nATC Mod'n 

Fee

Source Test 

Fee

App'n Fee for 

PTO Mod'nPTO Mod'n 

Fee

Source's 

Overall 

Fee 

Impacts

Plains Exploration & 

Production Companya 04632 - - -$2,404 -$162 -$1,076 - - - - - -$3,642

Purisima Hills LLC, Purisima 

Hills LLC - H.P. Boyne, 

Barham Ranch

01153 $325 $1,741 $725 $0 $323 $325 $1,741 $3,404 $325 $1,741 $10,651

Santa Maria Refining 

Company, Santa Maria 

Refining - Armelin

03736 $325 $1,107 $0 $0 $0 - - - - - $1,432

SBC Resource Recovery & 

Waste Mgmt Div., County of 

Santa Barbara - Foxen 

Canyon

03706 - - - - - $325 $513 $1,849 $325 $513 $3,525

Venoco, Inc., Venoco -

Ellwood, Platform Holly 01063 $325 $11,872 $596 $282 $204 - - $2,237 - - $15,516

Subtotals $4,550 $26,789 $12,051 $827 $6,901 $975 $2,254 $7,490 $975 $2,254

Fee Impact from the Initial Permitting of the 

ICEs Becoming Subject to Rule 201, Permits 

Required: $51,118b

Fee Impact from Engine Modifications to Comply 

with the Emission Limits: $13,949c

Total $65,067

 

a The fee decreases are due to 8 currently permitted engines becoming exempt under the proposed amended Rule 202.F.1.f provisions.

b

Sum of Columns 2 – 6.

c

Sum of Columns 7 – 11.
STAFF REPORT - Regulation II/Rule 333 Page L-5

June 19, 2008

Santa Barbara County APCD

Table 2. SUMMARY OF ANTICIPATED PERMIT REEVALUATION FEES REDUCED 

DUE TO CURENTLY PERMITTED ENGINES BECOMING EXEMPT 

BY THE PROPOSED AMENDED RULE 202a

STATIONARY SOURCE FACILITY SSID FID DEVICE No. DEVICE 

DESCRIPTION

RATING 

(Bhp)

REDUCED 

REEVAL FEES

E & B - South Cuyama E & B IC Engines 01073 08916 006338 IC Engine: W-40 24 $93

Pt. Pedernales/Lompoc Oil 

Fields Lompoc IC Engines 04632 04218 004495 IC Engine: #12020 46 $216

Pt. Pedernales/Lompoc Oil 

Fields Lompoc IC Engines 04632 04218 004498 IC Engine: #7440 46 $216

Pt. Pedernales/Lompoc Oil 

Fields Lompoc IC Engines 04632 04218 004504 IC Engine: #11605 39 $175

Pt. Pedernales/Lompoc Oil 

Fields Lompoc IC Engines 04632 04218 004505 IC Engine: #9709 46 $216

Pt. Pedernales/Lompoc Oil 

Fields Lompoc IC Engines 04632 04218 004506 IC Engine: #9305 46 $216

Pt. Pedernales/Lompoc Oil 

Fields Lompoc IC Engines 04632 04218 004508 IC Engine: #8501 46 $216

Pt. Pedernales/Lompoc Oil 

Fields Lompoc IC Engines 04632 04218 004509 IC Engine: #8483 46 $216

Pt. Pedernales/Lompoc Oil 

Fields Lompoc IC Engines 04632 04218 007034 IC Engine: #9229 46 $205

TOTAL $1,771

 

a Engines shown in Table 2 are currently permitted because the total aggregate of engines in the range of 20 to 100 bhp at the source exceeds 500 bhp. These 

engines are slated to become exempt because the total aggregate brake horsepower rating of the engines in the range of 20 to < 50 bhp at the source does not 

exceed 400 bhp.
STAFF REPORT - Regulation II/Rule 333 Page L-6

June 19, 2008

Santa Barbara County APCD

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STAFF REPORT - Regulation II/Rule 333 Page L-7

June 19, 2008

Santa Barbara County APCD

Table 3. SUMMARY OF THE ANTICIPATED COMPLIANCE COST IMPACTSa

Company Description and 

Stationary Source 

Description

Stationary Source No.Initial Source Test CostTotal Capital InvestmentAnnual Inspection and Monitoring CostsIncreased AnnualOperating & Maintenance Cost

Sum of the 

Listed Cost 

Impacts to 

the Source

Pacific Operators 

Offshore, LLC, Pacific 

Operators - Carpinteria

08001 $5,200 $4,000 $9,600 $4,000 $22,800

Purisima Hills LLC -

Barham Ranch, H.P. 

Boyne Lease

01153 $12,480 $12,000 $14,400 $12,000 $50,880

SBC Resource Recovery 

& Waste Mgmt Div., 

County of Santa Barbara -

Foxen Canyon

03706 $5,200 $4,000 $4,800 $4,000 $18,000

Venoco, Inc., Venoco -

Ellwood, Platform Holly 01063 $7,800 $0 $14,400 $0 $22,200

Total $113,880

RULE 333, CONTROL OF EMISSIONS FROM RECIPROCATING INTERNAL COMBUSTION ENGINES

Impacts from the proposed amended Rule 333 will occur for two general reasons: 1) the population of engines 

subject to Rule 333 is increasing and 2) Rule 333 requirements are being revised. Table 4 lists the engines that 

are or will become subject Rule 333. Engines that are/will be subject to the less than or equal to 200 hour per 

year recordkeeping provisions of Rule 333 are included in this table as well. 

Table 5 summarizes the revised Rule 333 provisions that will apply. The requirements are broken out based on 

engines being subject to certain exemptions or being subject to the Rule 333 emission limits. Table 5 includes 

notes on the requirements that are new and revised.

 

a Based on the 2005 Emission Inventory. These costs are in addition to any permitting or source testing fees 

assessed by the APCD.
STAFF REPORT - Regulation II/Rule 333 Page L-8

June 19, 2008

Santa Barbara County APCD

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STAFF REPORT - Regulation II/Rule 333 Page L-9

June 19, 2008

Santa Barbara County APCD

Table 4. ENGINES THAT ARE OR WILL BECOME SUBJECT RULE 333a

Company Description and 

Stationary Source 

Description

Stationary Source No.

Device No. Device

Becoming Subject to Rule 333Currently Subject to Emission LimitsBecoming Subject to Emission LimitsEngine is Exempt from Emission Limits Because it Burns Landfill GasCurrent Permit has a "< 200 Hours per Year" LimitEngines Becoming Subject to Rule 333 with Operations < 200 Hours per Year per 2005 Emission Inventory

b

Adams Services, Inc., Adams 

Services - Degassing 10242 009953 IC Engine: Degassing Unit X

BreitBurn Energy Company LP, 

BreitBurn Energy- Orcutt Hill 02667 004305& 004306 IC Engines: (#12205 & #12195) X

BreitBurn Energy Company LP, 

BreitBurn Energy- Orcutt Hill 02667 004434 & 004435

IC Engines: (#19766 & #12163 -

Fox Injection) X

City of Lompoc, City of 

Lompoc - WWT Plant 01708 001192, 001193, & 001194 IC Engines: Air Compressors X

DCOR, LLC, Platform Habitat 08012 004972, 004973, 

& 004985 

IC Engines: South Crane, North 

Crane, & Compressor X

DCOR, LLC, South 

County/Dos Cuadras, PF A 08003 004872 & 004873

IC Engines: South Crane & North 

Crane X

DCOR, LLC, South 

County/Dos Cuadras, PF B 08003 004886 & 004887

IC Engines: 15-Ton Pedestal 

Crane (South Crane) & 25-Ton 

Pedestal Crane (North Crane)

X

DCOR, LLC, South 

County/Dos Cuadras, PF 

Hillhouse

08003 004904 IC Engine: 15-Ton Pedestal 

(South) Crane X

DCOR, LLC, South 

County/Dos Cuadras, PF 

Hillhouse

08003 004905 IC Engine: 25-Ton Pedestal 

(North) Crane X

DCOR, LLC, South 

County/Dos Cuadras, PF C 08003 004923 IC Engine: 15-Ton Pedestal Crane (South Crane) X

 

a Based on the 2005 Emission Inventory.

b The APCD assumes that these engines will be subject to Rule 333 but exempt from the emission limits and the permit will have a condition limiting operations 

to less than 200 hours per year. 
STAFF REPORT - Regulation II/Rule 333 Page L-10

June 19, 2008

Santa Barbara County APCD

Company Description and 

Stationary Source 

Description

Stationary Source No.

Device No. Device

Becoming Subject to Rule 333Currently Subject to Emission LimitsBecoming Subject to Emission LimitsEngine is Exempt from Emission Limits Because it Burns Landfill GasCurrent Permit has a "< 200 Hours per Year" LimitEngines Becoming Subject to Rule 333 with Operations < 200 Hours per Year per 2005 Emission Inventory

b

DCOR, LLC, South 

County/Dos Cuadras, PF C 08003 004924 IC Engine: 25-Ton Pedestal Crane (North Crane) X

DCOR, LLC, South 

County/Dos Cuadras, PF Henry 08003 004938 IC Engine: 15-Ton Pedestal (South) Crane X

DCOR, LLC, South 

County/Dos Cuadras, PF Henry 08003 004939 IC Engine: 25-Ton Pedestal (North Crane) X

E & B Natural Resources Mgt. 

Corp., E & B - South Cuyama 01073

006388, 006389, 

006390, 006391, 

006392, 006393, 

006394, 006395, 

006396, 006397, 

006400, 006401, 

006402, 006403, 

& 006404

15 IC Engines: W-2, W-3, W-8, 

W-4, W-12 Wastewater Inj., W-11, 

W-15, W-42 Wastewater Inj., B-5 

Wastewater Inj., B-6, HRA #9, 

HRA #10, HRA #11, HRA #12, & 

Diesel Fired Unit

X

ExxonMobil Production 

Company, Exxon - SYU 

Project, PF Hondo

01482 004956 & 

004957 IC Engines: West and East Cranes X

ExxonMobil Production 

Company, Exxon - SYU 

Project, PF Harmony

01482 005326 Pedestal Crane East X

ExxonMobil Production 

Company, Exxon - SYU 

Project, PF Harmony

01482 005346 Auxiliary Drill Generator X X

ExxonMobil Production 

Company, Exxon - SYU 

Project, PF Heritage

01482 005350 Pedestal Crane East X

ExxonMobil Production 

Company, Exxon - SYU 

Project, PF Heritage

01482 005370 Auxiliary Drill Generator X X

Greka Oil & Gas, Inc., Casmalia 04630 004471 IC Engine: (#4gv1401) X
STAFF REPORT - Regulation II/Rule 333 Page L-11

June 19, 2008

Santa Barbara County APCD

Company Description and 

Stationary Source 

Description

Stationary Source No.

Device No. Device

Becoming Subject to Rule 333Currently Subject to Emission LimitsBecoming Subject to Emission LimitsEngine is Exempt from Emission Limits Because it Burns Landfill GasCurrent Permit has a "< 200 Hours per Year" LimitEngines Becoming Subject to Rule 333 with Operations < 200 Hours per Year per 2005 Emission Inventory

b

Greka Oil & Gas, Inc., Cat 

Canyon 02658

006466, 006467, 

006468, & 

007289

IC Engines: Gas Compressor 

(12253), Waukesha (110007- Inj. 

#2), #20 6LRZ (#912330) 

(NSCR), & Compressor #1 

#F3521GSI 

X

Greka Oil & Gas, Inc., Clark 

Avenue Source 02200 004178 & 004179

IC Engine: #912330 & IC Engine: 

#912331 X

Greka Oil & Gas, Inc., 

Continental 05032 003155 IC Engine: Well #2: (11705) X X

Greka Oil & Gas, Inc., Gato 

Ridge 02680

005203, 005204, 

005205, 005206, 

& 005207

IC Engines: Pumping Units X X

JEM Degassing, JEM Degassing 08685 006028 & 

006029

IC Engines: Degassing (#16828 

䆽) X

Lash Construction, Lash Const. 

(5 S. Calle Cesar Chavez ) 10309 010082 Diesel IC Engine (may be superseded by DID 107679) X

Mafi-Trench Corporation, MafiTrench 01717 001195 IC Engine: Air Compressor X

MM Tajiguas Energy LLC/NEO 

Tajiguas LLC, County of SBTajiguas Landfill03707 006523 IC Engine / Generator X

Nieto & Sons, Incorporated, 

Nieto & Sons - Degassing 08727 006027 IC Engine: Degassing Unit X

Pacific Operators Offshore, 

LLC, Pacific Operators -

Carpinteria, PF Hogan

08001 004848 IC Engine: South Crane X

Pacific Operators Offshore, 

LLC, Pacific Operators -

Carpinteria, PF Hogan

08001 004849 IC Engine: North Crane X

Pacific Operators Offshore, 

LLC, Pacific Operators -

Carpinteria, PF Houchin

08001 004860 IC Engine: South Crane X
STAFF REPORT - Regulation II/Rule 333 Page L-12

June 19, 2008

Santa Barbara County APCD

Company Description and 

Stationary Source 

Description

Stationary Source No.

Device No. Device

Becoming Subject to Rule 333Currently Subject to Emission LimitsBecoming Subject to Emission LimitsEngine is Exempt from Emission Limits Because it Burns Landfill GasCurrent Permit has a "< 200 Hours per Year" LimitEngines Becoming Subject to Rule 333 with Operations < 200 Hours per Year per 2005 Emission Inventory

b

Pacific Operators Offshore, 

LLC, Pacific Operators -

Carpinteria, PF Houchin

08001 004861 IC Engine: North Crane X

Pacific Operators Offshore, 

LLC, Pacific Operators -

Carpinteria, PF Hogan

08001 007107 IC Engine: Well Service Rig X X

a

Pacific Operators Offshore, 

LLC, Pacific Operators -

Carpinteria, PF Houchin

08001 007108 IC Engine: Well Service Rig X X

a

Plains Exploration & 

Production Company, Pt. 

Pedernales/Lompoc Oil Fields

04632 004494 IC Engine: Purisima # 86 (#12130) X

Plains Exploration & 

Production Company, Pt. 

Pedernales/Lompoc Oil Fields, 

PF Irene

04632 005082 & 

005083

IC Engine: North Crane & IC 

Engine: South Crane X

Purisima Hills LLC - Barham 

Ranch, H.P. Boyne Lease 01153

005908, 005909, 

005910, 005911, 

005912, & 

009015

IC Engines: Well Pumps & 

Natural Gas-Fired Unit X X

a

Santa Barbara Sand & Top Soil 

Corp., Santa Barbara Sand & 

Top Soil - Ellwood

03695 003318 Material Plant Diesel Engine X

Santa Maria Refining Company, 

Santa Maria Refining - Armelin 03736

005947, 005949, 

005950, & 

006231

IC Engines X X

SBC Resource Recovery & 

Waste Mgmt Div., County of 

Santa Barbara - Foxen Canyon

03706 104269 & 

106429

Diesel Fired IC Engines (Gen 4 

and 5) X

b

 

a Requires the use of an emission control technique.

b Requires the application of an enhanced emission control technique to both engines.
STAFF REPORT - Regulation II/Rule 333 Page L-13

June 19, 2008

Santa Barbara County APCD

Company Description and 

Stationary Source 

Description

Stationary Source No.

Device No. Device

Becoming Subject to Rule 333Currently Subject to Emission LimitsBecoming Subject to Emission LimitsEngine is Exempt from Emission Limits Because it Burns Landfill GasCurrent Permit has a "< 200 Hours per Year" LimitEngines Becoming Subject to Rule 333 with Operations < 200 Hours per Year per 2005 Emission Inventory

b

SBC Resource Recovery & 

Waste Mgmt Div., County of 

SB-Tajiguas Landfill

03707 106679 Diesel Fired IC Engine (WP01) X

Southern California Gas 

Company, So Cal Gas - La 

Goleta

05019

001199, 001200, 

001201, 001202, 

001203, 001204, 

001205, 001206, 

005666, 005667, 

005668, & 

005669

Eight Gas Compressor IC Engines: 

Number 2, 3, 4, 5, 6, 7, 8, & 9 

and four Electrical Generators: 

Number 1A, 2A, 3A, & 20A

X

The Point Arguello Companies, 

The Point Arguello Project, PF 

Harvest

01325 005000, 005001, 

& 00502

IC Engines: Cranes (800A, 800B, 

&CR801) X

The Point Arguello Companies, 

The Point Arguello Project, PF 

Hermosa

01325 005029 & 

005030 IC Engines: West & East Crane X

The Point Arguello Companies, 

The Point Arguello Project, PF 

Hidalgo

01325 005058 & 

005059 IC Engines: West & East Crane X

United States Air Force, 

Vandenberg Air Force Base 01195 006088 IC Engine: (Building 511) X

United States Air Force, 

Vandenberg Air Force Base 01195 006182 IC Engine: Electrical Generator (Building 7425) X

Vandenberg Air Force Base, 30 

CES/CEV, Vandenberg Air 

Force Base

01195 006184, 006185, 

& 006202

IC Engine (Hercules): Compressor, 

IC Engine (Deere): Compressor, & 

IC Engine: Diesel (Building 7437)

X

Venoco, Inc., Venoco -

Carpinteria 00027

000201, 000202, 

000203, 000204, 

000205, 00206, 

100222, & 

008166

Gas Compressor ICEs: IR #1, 

SACS Cooper (CA-83), IR #3, IR 

#4, IR #5, IR #6 & G-1; and a 

Diesel-Fired ICE

X

Venoco, Inc., Venoco - Ellwood 01063 002336 IC Engine: Pedestal Crane X

Venoco, Inc., Venoco - Ellwood 01063 009130, 009131, 

& 009132

IC Engines: Drilling Rig 

Generators #1, #2, & #3 X X
STAFF REPORT - Regulation II/Rule 333 Page L-14

June 19, 2008

Santa Barbara County APCD

Company Description and 

Stationary Source 

Description

Stationary Source No.

Device No. Device

Becoming Subject to Rule 333Currently Subject to Emission LimitsBecoming Subject to Emission LimitsEngine is Exempt from Emission Limits Because it Burns Landfill GasCurrent Permit has a "< 200 Hours per Year" LimitEngines Becoming Subject to Rule 333 with Operations < 200 Hours per Year per 2005 Emission Inventory

b

Venoco, Inc., Venoco - Ellwood 

Marine Terminal 01085 002437 & 002438

IC Engine: VRU & IC Engine: 

Generator X

Totals 23 78 11a1 20 12

 

a

Some of these engines already comply with the emission limits (e.g., Venoco‟s devices numbered 009130 – 009132). For a list of engines requiring an emission 

control technique or an enhanced emission control technique, see Appendix H, Table 1, Emission Reductions or see the items with footnotes “a” and “b” on page 

L-10.
STAFF REPORT - Regulation II/Rule 333 Page L-15

June 19, 2008

Santa Barbara County APCD

Table 5. SUMMARIZED RULE 333 REQUIREMENTS FUEL MONITORING AND RECORDKEEPING (333.B.1.a) ENGINE IDENTIFICATION METHOD (333.D.1) NONRESETTABLE ELASPED OPERATING TIME METER (333.D.2) NONRESETTABLE FUEL METER (333.D.3) RECORDKEEPING (333.J) ONGOING USE OF AN EMISSION CONTROL TECHNIQUE (333.E) NEW EMISSION CONTROL TECHNIQUE (333.E) CONTINUOUS MONITORING SYSTEM (333.D.4)

INSPECTION AND MAINTENANCE PLAN (333.F)REVISED I&M PLAN (333.F)COMPLIANCE PLAN (333.G)REVISED COMPLIANCE PLAN (333.G)SOURCE TESTING (333.I)

ENGINES EXEMPT FROM RULE 333 EMISSION LIMITS

1. ENGINES BURNING 75% LANDFILL 

GAS (333.B.1.a) X

2. PERMITTED ENGINES OPERATING < 

200 HOURS/YEAR (333.B.2) X X X

ENGINES SUBJECT TO RULE 333 EMISSION LIMITSa

3. TIERED COMPRESSION IGNITION 

ENGINES (333.B.3) - New Provision X X X X X

b X X X Xa

4. EXISTING ENGINES PREVIOUSLY 

SUBJECT TO RULE 333 EMISSION 

LIMITS

X X X X X X

a X X Xa

5. EXISTING ENGINES BECOMING 

SUBJECT TO RULE 333 EMISSION 

LIMITS

X X X X X

a X Xc Xa

6. NEW ENGINES X X X X X

a X X Xc Xa

 Table 6 is a summary of the proposed NOx emission limit changes.

 

a Emission limits for the following are being revised: Compression ignition engine NOx limits are being lowered slightly and new ROC and CO limits are being 

established for the first time. Lean-burn spark ignition engines rated in the 50 to less than 100 bhp range will have an increase in the NOx limit. Cyclically 

loaded rich-burn spark ignition engines will have an increased NOx limit. See Table 5 for additional details.

b

For ARB or EPA Tiered compression ignitions, this requirement is triggered if a portable analyzer reading exceeds 560 part per million of NOx at 15% oxygen 

on a dry basis.

c ARB or EPA Tiered compression ignitions are exempt from the requirement for a Compliance Plan per Rule 333.B.3.

REQUIREMENTS

S

CATEGORIES
STAFF REPORT - Regulation II/Rule 333 Page L-16

June 19, 2008

Santa Barbara County APCD

Table 6. SUMMARY OF THE PROPOSED NOx EMISSION LIMIT CHANGES

Engine Type Category

Number

Current NOx Limits Proposed NOx Limits Effect of Change % Control ppmva % Control ppmva

Rich-Burn NoncyclicallyLoaded Spark Ignition Engines 1 90 50 90 50 None 

Lean-Burn NoncyclicallyLoaded Spark Ignition Engines

in the 50 and greater to less 

than 100 bhp Range

2 80 125 - 200 Increased emission

limit

Lean-Burn NoncyclicallyLoaded Spark Ignition Engines

Rated 100 bhp or Greater

3 80 125 80 125 None

Cyclically-Loaded Spark 

Ignition Engines 4 90 50 - 300 Increased emission limit

Compression Ignition Engines 

and Dual-Fuel Engines 5 - 797 40 700 Decreased emission limit

Categories 1 and 3 have no changes to the NOx emission limits; therefore, there will be no impacts to engines in those categories. 

Categories 2 and 4 have increases to their emission limits. Without knowing if there are engines affected by these changes, these limit increases would seem to 

equate to higher emissions. However, the APCD inventory indicates that there are no currently permitted engines in Categories 2 or 4 that are subject to the Rule 

333 NOx limits. Therefore, there will be no increases in NOx emissions from Category 2 and Category 4 engines as a result of increasing the Rule 333 emission 

limits. 

Category 5 has a slight decrease in the NOx emission limit, but all engines currently subject to the emission limit are expected to comply with the lower limit by 

using low emission tuning techniques. 

On existing engines becoming subject to Rule 333 emission limits due to the permit exemption change, staff anticipates that the six engines in the 50 and greater 

to less than 100 brake horsepower range will be in Category 4. Further, these engines will comply with the emission limits by using the lean-burn tuning 

technique. The three offshore well drilling spark ignition engines becoming subject to the emission limits are expected to already comply with the Category 1 

limits. The two offshore well drilling compression ignition engines becoming subject to the emission limits are expected to comply by retarding the fuel injection 

timing and/or performing engine maintenance, if these engine do not already meet the Category 5 limits. Other Category 5 engines are expected to either already 

comply with the stricter emission limits or will be able to with additional injection timing retard tuning. 

 

a Dry, at 15% oxygen.
STAFF REPORT - Regulation II/Rule 333 Page L-17

June 19, 2008

Santa Barbara County APCD

APCD Impacts 

The influx of permit applications required by the Rule 202 engine exemption revision will create a short-term spike 

in workload. However, we will not be able to assess long-term impacts on workload until the applications have 

actually been submitted and we have issued the permits. Based on our emission inventory, we expect to receive 14

applications for 89 existing engines requiring permits due to the rule revision. The known engines that will require 

permits from the Rule 202 revision are identified in Appendix B.

In addition to the initial engine permits necessary because of the Rule 202 revision, there will be applications needed 

for the control techniques or enhanced control techniques to comply with the Rule 333 emission limits. Staff 

analysis indicates that there will be three applications for such control techniques on 10 engines. The engines 

requiring new or enhanced control techniques are listed in Appendix H, Table 1, Emission Reductions.

Adding engines to the population of engines subject to Rule 333 and enhancing the compliance requirements for 

engines subject to the emission limits will cause APCD workload impacts. Staff anticipates that 19 sources will need 

to submit revised Inspection and Maintenance Plans and Compliance Plans. Three stationary sources (01063, 01153, 

and 08001) will need to submit these plans for 11 engines that are becoming subject to Rule 333 emission limits for 

the first time (as shown in Appendix C or Appendix L, Table 3).

There will also be impacts due to additional engines needing to be inspected and source tested. Engines located 

offshore will require additional compliance logistics. Based on the APCD inventory, five of the engines becoming 

subject to the Rule 333 source testing requirements are located offshore. The other six engines are located at the 

Barham Ranch site (Northern Santa Barbara County). 

Staff may encounter additional permit exemption requests that do not relate to Rule 202.F.1.f. For example, sources 

may apply for the new specialty equipment exemption, the revised gas turbine exemption, or the new winery 

exemption. Staff expects that the applications for the specialty equipment exemption will occur infrequently due to 

the availability of equipment registered in the portable equipment registration program. Further, the number of 

sources seeking the revised gas turbine exemption or the winery exemption is anticipated to be in the one to three 

range. 
THIS PAGE INTENTIONALLY LEFT BLANK
STAFF REPORT - Regulation II/Rule 333 Page M-1

June 19, 2008

Santa Barbara County APCD

Appendix M

Santa Barbara County 

Overviews of Proposed Amended Rule 333 Provisions on Applicability; Engine 

Identification, Meters, and Continuous Monitoring Systems; Emission Limits; and 

Compliance Schedule

Figure 1. Rule 333 Applicability and Exemption Provisions.

1

Equipment Includes 

a Piston-Type Internal 

Combustion Engine 

(ICE).

1

Rule 333 

Exempt.

1. These flowcharts are presented on an informational basis to assist the reader in understanding the requirements . 

If there is any conflict between the flowcharts and the rule, rule text takes precedent.

No

Is the 

ICE Rated at 50 

Brake Horsepower 

(Bhp) or 

Greater?

(See 333.A)

Has 

the ICE Been 

Derated?

No

Yes

Was 

the Original 

Equipment Manufacturer 

(OEM) Rating for the ICE 

50 Bhp or 

Greater?

Yes

No

Yes

Rule 333 

Is Not Applicable No

Is 

the ICE Exempt

from Permit per 

Rule 202?

Yes

No

(See 333.B.1.b)

Is 

the ICE Derated 

and Permitted 

Below 

50 Bhp?

Yes

(See 333.B.1.c)

Is the 

ICE a Compression 

Ignition Emergency 

Standby Engine (as 

Defined in the State 

ATCM)?

Yes

No

(See 333.B.1.d. The definition of an 

“Emergency Standby Engine” is in 

Section 93115 of Title 17 of the 

California Code of Regulations)
STAFF REPORT - Regulation II/Rule 333 Page M-2

June 19, 2008

Santa Barbara County APCD

Figure 1. (cont.)1

1

1. These flowcharts are presented on an informational basis to assist the reader in understanding the requirements . 

If there is any conflict between the flowcharts and the rule, rule text takes precedent.

No

No

Is the 

ICE Operated 

Less than or Equal 

to 200 Hours per 

Year?

Does 

the ICE have 

Identification and an 

Elapsed Operating 

Time Meter?

No

Yes

No

Yes

(See 333.B.2. There is 

additional Provisions 

Concerning Relocated 

Engines.)

Rule 333 

Exempt.

No

Ensure the ICE has 

Identification Within the 

One Month Compliance 

Period in 333.K.2.c.i.

Ensure the ICE has an 

Elapsed Operating Time 

Meter Within the Six 

Month Compliance 

Period in 333.K.2.c.ii.

Is 

the ICE a 

Compression Ignition 

Engine?

Is the 

ICE Subject to 

any State or Federal 

Tiered Engine 

Limit?

Yes

(See 333.B.3)

The ICE is Exempt from 

the 333.G, Compliance 

Plan, Requirements, But 

is Subject to the Other 

Rule 333 Provisions 

(Unless Otherwise 

Indicated).

Yes

No

Yes

Is

the ICE 

a Spark Ignition 

Engine Burning 

Landfill 

Gas?

No No

(See 333.B.1.a for 

Additional Requirements 

that Apply.)

Does 

the ICE Burn Fuel 

That is 75% Landfill Gas 

or More on an 

Annual 

Basis?

Yes

Submit, with the Authority to 

Construct application, Written 

Documentation of Fuel Usage 

Verification Methods, Install 

and Maintain Meters, and Keep 

Records. Obtain the APCO's 

Approval of the Documentation

(See 333.B.1.a)

End of 333.B 

Exemptions.

(See 333.D.1 and D.2)

Is the

ICE Owner or 

Operator Performing the

Recordkeeping per 

333.J.3?

Yes

Ensure the Recordkeeping 

Provisions are Being Met 

Within the One Month 

Compliance Period in 

333.K.2.c.i.
STAFF REPORT - Regulation II/Rule 333 Page M-3

June 19, 2008

Santa Barbara County APCD

End of 333.D 

Requirements.

No

(See 333.D.1)

Figure 2. Rule 333 Provisions on Engine Identification, Meters, and 

Continuous Monitoring Systems.

1

1. These flowcharts are presented on an informational basis to assist the reader in understanding the requirements . 

If there is any conflict between the flowcharts and the rule, rule text takes precedent.

Is

the ICE a New 

Engine Rated at 

1,000 Bhp or 

Greater?

Is

the ICE Subject to 

Rule 333 Emission 

Limits?

Is

the ICE Subject 

to a PTO Allowing 

Operations in excess of 

2,000 Hours per 

Year?

The Engine is to be Identified With a Permanently 

Affixed Plate, Tag, or Marking, Listing:

A. The Engine's Make, Model, and Serial Number; or

B. The Owner's or Operator's Unique Identification 

Number.

The Plate, Tag, or Marking Shall be Made Accessible 

and Legible.

The Engine Shall be Equipped 

With a Nonresettable Elapsed 

Operating Time Meter. The 

Owner or Operator Shall Ensure 

That the Meter is Maintained in 

Proper Operating Condition.

The Engine Shall be Equipped With a 

Nonresettable Fuel Meter or an Alternative 

Device, Method, or Technique in Determining 

Fuel Consumption, Provided the Alternative 

is Approved by the Control Officer. The Fuel 

Meter Shall be Calibrated Periodically per the 

Recommendations of the Manufacturer. The 

Owner or Operator Shall Ensure that the 

Meter Is Maintained in Proper Operating 

Condition.

Yes

Yes

Yes

No

No

ICE Requires a 

Continuous NOx and O2 

Monitoring System 

Approved by the Control 

Officer

(See 333.D.2)

(See 333.D.3. Some ICEs 

may be Exempt from the 

Fuel Metering Requirement.)

(See 333.D.4)

(See 333.D.4 for More Details 

Concerning the Continuous 

Monitoring System Requirements.)

(See 333.D.4.a)

(See 333.D.4.c)

(See 333.D.4.c)

Was 

the ICE Installed

on or After [Date of 

Revised Rule 

Adoption]?

Yes

(See 333.D.4.b)

No

Equipment Includes 

an ICE Rated at 50 

Bhp or Greater that 

is Not Exempt from 

Section 333.D 
STAFF REPORT - Regulation II/Rule 333 Page M-4

June 19, 2008

Santa Barbara County APCD

End of Applicable 

333.E Requirements 

for the Noted ICE 

Category.

Equipment Includes 

an ICE Rated at 50 

Bhp or Greater that is 

Subject to Section 

333.E, Emission 

Limits 

Figure 3. Rule 333 Emission Limits.

1

1. These flowcharts are presented on an informational basis to assist the reader in understanding the requirements . 

If there is any conflict between the flowcharts and the rule, rule text takes precedent.

Engine Owners/Operators Shall 

Meet the Following Requirements 

In Accordance with the Compliance 

Schedule Set Forth in Section K.

Is the 

Engine a Rich-Burn 

Noncyclically-Loaded 

Spark Ignition

ICE?

Meet the Following Parts 

per Million by Volume 

(ppmv) Limits (at 15% O2)

NOx 50

ROC 250

CO 4,500

Yes

Does 

the ICE Have a 

Combustion Modification 

or Use Exhaust Control 

Equipment?

No

Yes

Meet the Following ppmv Limits (at 15% O2)

NOx 50a

ROC 250

CO 4,500

aAlternatively, Reduce NOx by at Least 90 

Percent by Mass.

Is the 

Engine a LeanBurn Cyclically- or 

Noncyclically-Loaded 

Spark Ignition 

ICE?

Meet the Following 

ppmv Limits (at 15% O2)

NOx 125

ROC 750

CO 4,500

Yes

Does 

the ICE Have a 

Combustion Modification 

or Use Exhaust Control 

Equipment?

No

Yes

Meet the Following ppmv Limits (at 15% O2)

NOx 125a

ROC 750

CO 4,500

aAlternatively, Reduce NOx by at Least 80 

Percent by Mass.

No

Does the 

ICE Have a Rated 

Brake Horsepower of 50 

or Greater but Less 

Than 100?

Meet the Following 

ppmv Limits (at 15% O2)

NOx 200

ROC 750

CO 4,500

Yes

No

1

No

(See 333.E.1)

(See 333.E.1.a)

(See 333.E.1.b)

(See 333.E.2.b)

(See 333.E.2.a)

(See 333.E.2.a)

(See 333.E.2)

The Use of Anhydrous Ammonia to 

Meet the Requirements of this Rule 

is Prohibited Unless Case-Specific 

Analysis Indicates that the Use is 

Acceptable to the Control Officer.

(See 333.E.5)

(See 333.E)
STAFF REPORT - Regulation II/Rule 333 Page M-5

June 19, 2008

Santa Barbara County APCD

1

Figure 3. (cont.)1

1. These flowcharts are presented on an informational basis to assist the reader in understanding the requirements . 

If there is any conflict between the flowcharts and the rule, rule text takes precedent.

End of Applicable 

333.E Requirements 

for the Noted ICE 

Category.

Is the 

Engine a Rich-Burn 

Cyclically-Loaded SparkIgnition ICE?

Meet the Following 

ppmv Limits (at 15% O2)

NOx 300

ROC 250

CO 4,500

Yes

(See 333.E.3)

Meet the Following 

ppmv Limits (at 15% O2)

NOx 700

ROC 750

CO 4,500

Does 

the ICE Have a 

Combustion Modification 

or Use Exhaust Control 

Equipment?

No

Yes Meet the Following ppmv Limits (at 15% O2)

NOx 700a

ROC 750

CO 4,500

aAlternatively, Reduce NOx by at Least 25 

Percent by Mass.

(See 333.E.4)

(See 333.E.4.a)

(See 333.E.4.b)

No

The Engine is a Compression 

Ignition or Dual-Fuel ICE.
STAFF REPORT - Regulation II/Rule 333 Page M-6

June 19, 2008

Santa Barbara County APCD

Figure 4. Rule 333 Compliance Schedule Provisions.

1

1. These flowcharts are presented on an informational basis to assist the reader in understanding the requirements. 

If there is any conflict between the flowcharts and the rule, rule text takes precedent.

(See 333.K.2.a)

Does 

the Owner or 

Operator Claim that the 

Engine is Exempt by 

333.B.2?

Yes

(See 333.K.2.c)

By [One Month from the Date 

of Revised Rule Adoption], 

Comply With the 

Recordkeeping Provisions in 

Section J.3.

By [Six Months from the Date 

of Revised Rule Adoption], 

Install and Comply with the 

Metering Requirements in 

333.D.2.

(See 333.K.2.c.ii)

(See 333.K.2.c.i)

End of Applicable 

333.K Requirements 

for ICEs in this 

Category.

Was 

the ICE Subject 

to an Emission Limit in 

the April 17, 1997 

Adopted Rule 

333?

Is the 

ICE Subject to

a Revised Rule 

333 Emission 

Limit?

Continue to Comply with 

Emission Limits in the April 

17, 1997 Adopted Rule 333 

Until Such Time that 

Compliance with a Revised 

Emission Limit is Required.

Yes

By [Six Months from the Date 

of Revised Rule Adoption], 

Submit a Statement to the 

Control Officer Identifying the 

Engine to be Removed.

By [Two Years from 

the Date of Revised 

Rule Adoption], 

Remove the Engine.

(See 333.K.2.b.ii)

The Owner or Operator of any Engine 

to be Modified or Replaced to Comply 

with the Section E Emission Limits 

Shall Submit an Authority to 

Construct Application to the Control 

Officer by [One Year from the Date 

of Revised Rule Adoption].

An Initial Source Test Demonstrating 

Compliance with a New or Revised 

Emission Limit Shall be Completed in 

Accordance with Section I Prior to 

[Two Years from the Date of Revised 

Rule Adoption].

(See 333.K.2.b.iii)

Yes

End of Applicable 

333.K Requirements 

for ICEs in this 

Category.

(See 333.K.2.a)

(See 333.K.2.a)

(See 333.K.2.d.i)

1

No

Equipment Includes 

an ICE Rated at 50 Bhp 

or Greater that is 

Subject to at Least One 

Rule 333 Requirement

(See 333.K.1 and the 333.C 

definition of "New Engine.")

Is the

Engine a "New" 

Engine

Yes

No

Commencing [Date of 

Revised Rule Adoption], 

Any New Engine Shall 

Comply With this Rule the 

First Time it is Operated. 

By [One Month from the Date 

of Revised Rule Adoption], 

Comply With the Engine 

Identification Requirements in 

333.D.1.

(See 333.K.2.b.i, K.b.c.i, 

or K.b.d.i)

Will 

the Engine be 

Permanently 

Removed from 

Service ?

(See 333.K.2.a)

Unless the ICE is Permanently Removed, Any 

ICE 1) Subject to a Revised Emission Limit, or 

2) That Was Previously Exempt from Rule 333, 

But Became Subject to Rule 333 Emission 

Limits Through the [Date of Revised Rule 

Adoption] Rule 202 Revisions, Shall Comply 

with the Emission Limits by [Two Years from the 

Date of Revised Rule Adoption].

Yes

No

No

(See 333.K.2.b)

(See 333.K.1 for 

Additional Details.)

No

By [One Month from the Date 

of Revised Rule Adoption], 

Comply With the 

Recordkeeping Provisions in 

Section J.

By [Nine Months from the Date 

of Revised Rule Adoption], 

Install and Comply with the 

Metering Requirements in D.2 

and D.3.

(See 333.K.2.d.iii)

(See 333.K.2.a)
STAFF REPORT - Regulation II/Rule 333 Page M-7

June 19, 2008

Santa Barbara County APCD

Figure 4. (cont.)1

1. These flowcharts are presented on an informational basis to assist the reader in understanding the requirements . 

If there is any conflict between the flowcharts and the rule, rule text takes precedent.

1

(See 333.K.2.d.ii)

Has

the ICE Owner or

Operator Previously 

Obtained the APCO’s 

Approval for an I&M Plan 

or a Compliance

Plan?

Does

the Previously 

Approved Plan(s) 

Comply with the 

Revised 

Rule?

Yes

Yes

No

No

Submit a Request for the 

APCO’s Concurrence that the 

Plan(s) is Adequate. 

(See 333.K.2.d.ii.2)

End of 

333.K Requirements.

By [Six Months from the Date of Revised 

Rule Adoption], Submit a New/Revised 

Engine Inspection and Maintenance Plan 

for the Control Officer's Approval Pursuant 

to Section F. Any Previously Approved 

Engine Inspection and Maintenance Plan 

will Continue to be in Force Until the 

Control Officer Approves a Revised Plan.

Does 

the APCO Concur 

that the Plan(s) is 

Adequate?

No

(See 333.K.2.d.ii.1)

Yes

Is the 

ICE a Compression 

Ignition Engine Subject to 

a State or Federal 

Tiered Engine 

Limit?

No

(See 333.B.3)

(See 333.F & G)

By [Six Months from the Date of Revised 

Rule Adoption], Submit a New/Revised 

Compliance Plan for the Control Officer's 

Approval Pursuant to Section G. 

Previously Approved Compliance Plans 

will Continue to be in Force Until the 

Control Officer Approves a Revised 

Compliance Plan.

Yes

The ICE is Exempt from the 

Requirement to Have a 

Compliance Plan.

(See 333.B.3)
THIS PAGE INTENTIONALLY LEFT BLANK
STAFF REPORT - Regulation II/Rule 333 Page N-1

June 19, 2008

Santa Barbara County APCD

Appendix N

Santa Barbara County 

Frequently Asked Questions (Ver. 1.5)a

Frequently Asked Questions 

Rule 202 - Exceptions to Rule 201

 Temporary Equipment

 Temporary Equipment – Short Term Use

 Temporary Equipment – Examples*

 Temporary Equipment – Method for Determination Compliance with the 60-day and 1 ton per 12 Months 

Provision

 Equipment “Stacking”

 Construction

 Construction – Projected Actual Emissions and Offsets

 Construction Engines

 Derated Engines - Permitting Requirements

 Derated Engines - Certifications and Enforceable Deratings

 Solvent Wipe Cleaning Exemption Recordkeeping

 Engine Electronic Fuel Metering

 Various Location Equipment Exemption

Temporary Equipment [Existing FAQ on the SBCAPCD Web Site]

Q: Please clarify the temporary equipment exemption. What is the distinction between the 60 day period limit and 

the consecutive 12 month period? For adding up the emissions for a source to comply with the 1 ton limit, do we total

all the temporary equipment emissions or do we treat each emissions unit separately with its own emission limit?

A: The 60 day period applies to individual emission units and limits any one unit from operating under the exemption 

for any time period exceeding 60 days. This 60 day period must be within a consecutive time frame and is not 

intended to allow for sporadic use through out the year. The 12 month consecutive time period ensures that the 

intent of the exemption is maintained by disallowing use of the same emission unit for a 120 day period if the 

calendar year basis was used. The 1 ton limit applies all emission units within a consecutive 12 month period.

Temporary Equipment – Short Term Use [Existing FAQ on the SBCAPCD Web Site]

Q: Does the Temporary Equipment exemption (Section D.5) include short term operation of permitted equipment in 

a way that is not permitted, say a short term trial of equipment limits, or a "fault finding" search to determine why 

equipment can't quite meet BACT requirements under certain conditions?

A: No. The exemption is for new equipment only. Testing, shake-down and debugging activities for compliance with 

BACT standards is why the APCD has a Source Compliance Demonstration Period during the construction phase 

(i.e., with ATC permit issuance). Once the source has a Permit to Operate, they may seek administrative relief via 

APCD Regulation V (Variances).

 

a Upon adoption of the proposed amended Rule 202, the APCD intends to place these proposed FAQs on the 

SBCAPCD Web Page (i.e., the Web Page at: http://www.sbcapcd.org/eng/nsr/faq_202.htm#201-1). To provide a 

comprehensive overview of the existing and proposed FAQs, this document includes the existing FAQs that 

interrelate to proposed new FAQs. 
STAFF REPORT - Regulation II/Rule 333 Page N-2

June 19, 2008

Santa Barbara County APCD

Temporary Equipment – Examples [Existing FAQ on the SBCAPCD Web Site]

Q: Examples of temporary activities that qualify for the temporary equipment exemption (202.D.5) include, but are 

not limited to:

A:

 ICE's from cranes, welders, jack hammers, etc. used during the demolition of a source or part of a source. 

 Replacement or use of equipment during a breakdown situation. 

 Demonstration equipment being used to determine feasibility (not lab test equipment). 

 Any short-term, one-time project that requires equipment that pollutes is eligible if it meets the 1 ton criteria 

of all affected pollutants. The Portable Equipment Registration Rule is intended to handle portable 

equipment that emits more and is used for longer periods of time. 

 While written notification is required, the project may commence as soon as notification is made without 

waiting for approval from the APCD. However, if a project commences with equipment that is later found not 

eligible for the exemption, the commencement will constitute a violation of the APCD's Rules and 

Regulations 

Temporary Equipment – Method for Determination Compliance with the 60-day and 1 ton per 12 

Months Provision

[Reference Proposed Amended Rule 202.D.5]

Q: Can the APCD clarify how the 60-day provision works in practice? That is, how compliance with the rule’s 60 

days and 1 ton per 12 months provisions are determined.

A: The 60 day time period is a continuous period starting the first day the equipment is used. Once started, the 60 

day period is not stopped and re-started. The equipment may be used any time within the 60 day period and may 

leave and return to the site. Compliance with 60 day requirement is based on the start date. Compliance with the 1 

ton requirement is based on a compilation of the consecutive 12-month emissions as provided in the company’s 

written exemption requests. Multiple temporary projects are allowable within the consecutive 12-month period 

provided 1) the aggregate 1-ton threshold is not exceeded, 2) the equipment is not used for more than 1 project, and 

3) each individual project is not used for more than 60 consecutive days.

Equipment “Stacking” [Reference Proposed Amended Rule 202.D.15]

Q1: How is it determined that equipment is “stacked” or “used in the same process”?

A1: The APCD uses the engineering basis and system demands to determine that equipment is “stacked” or “used 

in the same process.” Such analysis will involve looking at the equipment’s or system’s maximum energy needs or 

demands under a worst-case scenario.

 Example 1: A design basis is such that ten 1 million British thermal units per hour (MMBtu/hr) boilers can 

be required at any one time. For this case, we would consider that equivalent to a single 10 MMBtu/hr 

boiler.

 Example 2: A source installs two 4 MMBtu/hr boilers that are fired exclusively on natural gas. One is for 

primary use and one is standby. The design heat demand is 4 MMBtu/hr. Thus, the boilers in this 

configuration are not considered to be used in the same process (stacking). 

 Example 3: An electric generator has two 30 brake horsepower internal combustion engines that drive a 

single shaft concurrently. The power demands are such that both engines typically need to run 

simultaneously. The configuration is considered to be used in the same process and a total rating of 60 
STAFF REPORT - Regulation II/Rule 333 Page N-3

June 19, 2008

Santa Barbara County APCD

brake horsepower would be used for determining permitting applicability (but Rule 333 would not be 

applicable).

Q2: A source is not sure if its existing equipment configuration constitutes “equipment stacking” and may require 

permitting. How can the source get an SBCAPCD determination about the configuration and its 

exemption/permitting status?

A2: The source should complete an APCD Form - 38, “Request for Written Determination of Permit Exemption,” and 

submit it along with the fee. 

Q3: Will stacked equipment be subject to the requirements of the prohibitory rules and other regulations?

A3: Stacked equipment is subject to NSR provisions (e.g., BACT) for all units as one. For control measures such as 

Rule 342 and Rule 333, each unit is individually assessed for rule applicability.

Construction [Existing FAQ on the SBCAPCD Web Site]

Q: In Section F.3 (IC Engines), does the 25 ton limit include fugitive dust emissions associated with the construction 

operation?

A: Yes. The 25 ton threshold applies to all pollutants emitted during the construction process. Also, the 25 ton 

threshold applies to each pollutant, and is not aggregated.

Construction – Projected Actual Emissions and Offsets

[Reference Proposed Amended Rule 202.D.16]

Q1: How are fugitive dust emissions calculated when mitigation techniques are used?

A1: The potential to emit is determined taking into account the dust mitigation techniques. These assessments are 

done on a case-by-case basis using the best available emission calculations tools. 

Q2: At what point would the 25 tons per year offset requirement for construction equipment be necessary? 

A2: Offsets are required prior to exceeding the 25 tpy projected actual emissions threshold. That is why the term 

“projected” is used.

Q3: There is a concern that an interpretation might be made that includes all construction projects within a 

stationary source for the 25 ton total. For example, industry does not believe that a water line project and/or 

construction of a building within a large stationary source, not requiring an ATC, are subject to this 25 ton cap. This 

is analogous with other construction projects occurring in Santa Barbara County (e.g., Housing developments, large 

parking structures, or UCSB construction projects).

A3: The method for determining that a construction activity may be subject to offsets under the proposed new Rule 

202.D.16 provision will be the same method used for the current Rule 202.F.3 provision. Only construction projects 

involving ATC permits are subject to this requirement.

Q4: Can the offset provisions be applied on a project or facility basis?

A4: No. Current Rule 202.F.3 specifies the requirement is for construction equipment used to construct a stationary 

source that requires an ATC. The proposed new Rule 202.D.16 text is essentially the same as current Rule 202.F.3. 

Stationary sources may opt to tally the total stationary source construction emissions on a project or facility basis, 

but the offset requirement is triggered on a stationary source basis; not on a project or facility basis.
STAFF REPORT - Regulation II/Rule 333 Page N-4

June 19, 2008

Santa Barbara County APCD

Q5: A person proposes to build a new stationary source that requires an Authority to Construct. The construction 

emissions have a projected actual NOx emission rate in excess of 25 tons per year and the post-construction 

stationary source will have a net emissions increase of 40 tons of NOx per year. What are the emission offset 

implications for such a project? 

A5: Per Rule 202.D.16, offsets are required for the project because the actual projected emission rate is in excess 

of 25 tons per year. The ATC permit will document the source of emission reduction credits to be used to offset this 

construction emission offset liability. For the operational phase, offsets are triggered per Rule 802.E. Emission 

reduction credits applied to the construction phase offset liability may also be used to offset the operational phase 

liability (this assumes that there are no restrictions on the use of the ERCs and that the construction phase was 

completed). 

Construction Engines [Reference PAR 202.D.16 and Current Rule 202.F.2]

Q: Who is responsible to get the permit or a PERP for a construction engine, the contractor or the source?

A: Ultimately the stationary source will be held accountable for the permitting or registering in the PERP of 

construction engines. The APCD recommends that sources put something in their request for bids or contracts 

requiring that all construction engines be registered in the PERP or be permitted.

Derated Engines - Permitting Requirements

[Reference Proposed Amended Rule 202.F.1.e - g]

Q: Will my derated engine need to be permitted?

A: Yes, unless the engine rated brake horsepower before the derating was such that the engine would not require a 

permit.

 Example 1: A diesel engine with an original manufacturer’s nameplate rating of 48 brake horsepower is 

derated to 40 brake horsepower. Under Rule 202.F.1.e, the engine with the original manufacturer’s 

nameplate rating of 48 brake horsepower was exempt. Thus, the derated engine is exempt. 

 Example 2: A spark ignition engine with an original manufacturer’s nameplate rating of 75 brake 

horsepower is derated to 40 brake horsepower. Under proposed amended Rule 202.F.1.f, the engine had 

an original rating of 75 brake horsepower, which is above the 50 or greater brake horsepower permitting 

threshold. Thus, the derated engine requires a Permit to Operate (PTO).†

 EXAMPLE 3: A spark ignition engine with an original manufacturer’s nameplate rating of 45 brake 

horsepower is derated to 25 brake horsepower and it is located at a source that requires engines in the > 

20 to < 50 brake horsepower to be permitted. Under proposed amended Rule 202.F.1.f, the engine with an 

original rating of 45 brake horsepower is not exempt. Thus, the derated engine requires a PTO.†

 EXAMPLE 4: A source has eleven spark ignition engines only. These engines are derated. Each of the 

engine original equipment manufacturer (OEM) nameplate ratings (before derating) is 40 brake horsepower. 

Thus, a tally of the OEM nameplate ratings for these engines equals 440 brake horsepower (11 engines 

times 40 brake horsepower/engine). Since the aggregate exceeds 400 brake horsepower, all engines need 

a permit. The owner or operator cannot permit just 2 engines derated to 10 brake horsepower so the 

aggregate becomes 380 [(2 engines times 10 brake horsepower/engine) + (9 engines times 40 brake 

horsepower/engine)] and get an exemption for the other 9 engines. Once the requirement to permit all 

engines in the > 20 to < 50 brake horsepower range has been triggered, they shall not become exempt by 

the application of the derated brake horsepower ratings. Ratings of engines permanently removed will be 

excluded from new aggregate totals assessed pursuant to Authority to Construct modifications. †

________________________ 

† Figure 1 (available here) shows an overview of the Rule 202.F.1.f permit exemption provisions.
STAFF REPORT - Regulation II/Rule 333 Page N-5

June 19, 2008

Santa Barbara County APCD

Derated Engines - Certifications and Enforceable Deratings

[Reference Proposed Amended Rule 202.F.1.e - g]

Q1: My derated engines have been previously listed on a SBCAPCD PTO. Will I need to have additional derating 

certifications or power rating tests performed on my engine under the revised rules?

A1: If the engine deratings are (1) not enforceable and (2) not APCD-approved on a Permit to Operate, then 

submittal of the documentation may be necessary. It is suggested that sources with engines in this category work 

closely with the Engineering & Compliance Division staff to determine what information needs to be submitted and

what information is already on file with the APCD. 

Q2: If the engine manufacturer re-issues an engine nameplate to reflect the engine’s new continuous brake 

horsepower rating with an orifice plate or some other kind of physical limiting method, can the rating on the re-issued 

nameplate be considered to be the engine’s rated brake horsepower?

A2: No, the APCD will use the engine manufacturer’s originally issued nameplate as the engine’s brake horsepower 

rating, unless the APCD issues a PTO for the derated engine. For the purposes of Rule 333 applicability, the APCD 

will consider an engine that has an enforceable derating, that has been certified, and is subject to a PTO to have a 

modified rated brake horsepower based on the derated brake horsepower figure.

Q3: My company has several unpermitted derated engines. Will I need to submit certification documentation to 

substantiate the engine deratings?

A3: The answer is “Yes.” If a permit is required for the ICEs, then certification documentation will need to be 

submitted.

The APCD needs to issue PTOs for derated engines that would otherwise require a permit to ensure that the engine 

deratings are enforceable and maintained. The derating certification data needs to be submitted with the PTO 

application. It is suggested that sources with engines in this category work closely with the Engineering & 

Compliance Division staff to determine acceptable material that needs to be submitted with the application. 

Q4: My engine has an orifice plate inserted between the carburetor and the engine’s intake manifold. There is a tab 

on the orifice plate that clearly shows the size of the orifice. Is this sufficient to show my engine is properly derated?

A4: Assuming that the engine was derated and certified as derated by procedures approved by the APCD and it is 

subject to a permit, it is not enough that the orifice plate’s tab is stamped correctly. We have physically checked 

orifice plates and found that they can deteriorate overtime. Thus, it is necessary that the orifice plate actually be in 

compliance with the specifications as well as being marked with its appropriate size. 

Q5: I believe my company derated engines from 75 brake horsepower to < 50 brake horsepower. But, there are no 

permits for them to reflect their deratings because they have always been exempt under the 500 brake horsepower 

exemption provision. How do I obtain a concurrence from the APCD that these engines are derated?

A5: These engines will require permits under the proposed revised Rule 202. Information on the deratings should 

be submitted with the applications for Permit to Operate. Depending on the method of derating and past derating 

certification documentation, additional analysis may be required. 
STAFF REPORT - Regulation II/Rule 333 Page N-6

June 19, 2008

Santa Barbara County APCD

Solvent Wipe Cleaning Exemption Recordkeeping [Reference Current Rule 202.U.3]

Q: As an operator of a large complex with several stationary sources and several facilities, am I permitted to track 

solvent use on a facility basis?

A: Yes, as long as each facility solvent use is totaled for the stationary source for determining compliance with the 

Rule 202.U thresholds. Rule 202.U has an overall 10 tons per year threshold. Rule 202.U.2 has a solvent tank area 

aggregate threshold of 10 square feet for tanks with less than 1 square foot of area. And, Rule 202.U.3 has a wipe 

cleaning threshold of 55 gallons per year. 

Designation of facilities and facility numbers are a construct of the APCD permitting process. Facilities are a subset 

of stationary sources. Thus, if an operator of a large complex desired to track solvent usage on a facility basis, the 

APCD would not have a concern, provided the operator properly aggregates all of the facility solvent usage and tank 

area data within the stationary source and is able to provide the stationary source data in support of exemption 

claims.

Engine Electronic Management Fuel Metering

Q: Will the APCD accept onboard electronic engine fuel metering systems?

A: Yes, on an engine model-by-model basis and if the engine is set up to display the totalized fuel reading without 

the need to have an engine technician on site to retrieve the data. Monthly fuel readings are still required to be 

logged. For each engine fuel metering system, the APCD will require an initial validation test using an external 

calibrated fuel meter as well as a fuel use monitoring plan for the permit. 

Various Location Equipment Exemption 

Q: What is the basis for the various equipment exemption under Rule 202.D.17?

A: This new exemption was added to allow for the use of permitted “various locations” equipment at existing 

stationary sources where the equipment is not owned by the stationary source using the equipment. The intent of 

this exemption is to allow for the use of equipment for repair or maintenance related activities without the need for 

the stationary source owner or operator to comply with the New Source Review regulations. The equipment owner 

or operator will have a District Permit to Operate that specifically states that the equipment can be used at various 

locations and has conditions related to District notification and other restrictions of use. The type of activities 

envisioned for this exemption primarily includes tank degassing equipment and tank bottoms dewatering equipment. 
STAFF REPORT - Regulation II/Rule 333 Page N-7

June 19, 2008

Santa Barbara County APCD

Figure 1. Overview of the Rule 202.F.1.f permit exemption provisions for spark ignition internal combustion engines.

1 1. These flowcharts are presented on an informational basis to assist the reader in understanding the requirements. If there is any conflict between the flowcharts and the rule, rule text takes precedent.

A Determination of the Rule 202.F.1.f Exemption Applicability is Needed for a Spark Ignition Internal Combustion Engine (ICE).

Is the ICE’s Original Equipment Manufacturer’s (OEM’s) Rating Less than 50 Bhp?

No

Permitting Required.

Is the ICE’s OEM’s Rating 20 Bhp or Less? Yes Yes

Permit Exempt.

No

Is the ICE at a Stationary Source Where the Aggregate Figure for ICEs in the > 20 to < 50 Bhp Range ≥ 400 Bhp? Bhp Ratings are Based on OEM’s Ratings, Not on any Derated Bhp Ratings.

Yes No

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