UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION IX 

75 Hawthorne Street 

San Francisco, CA 94105 

March 9, 2006 

Kurt Kaiperos, Chief 

Air Quality & Transportation Planning Branch 

California Air Resources Board 

P.O. Box 2815 

Sacramento, CA 95812-2815 

Subject: RACT SIPs 

Dear Mr. Karperos; 

As you know, 40 CFR 51.912 requires CARB to submit RACT SIPs for many parts of 

California. We appreciate efforts to date by State and District staff to develop these SIPs and we 

recognize that some details of the requirement remain unresolved. This letter is intended to help 

clarify our understanding of the requirements and respond to a few of the questions recently 

raised by the State. 

Submittal Schedule - Clean Air Act Title 1, Part D, Subpart 2 areas classified as moderate and 

higher must submit a RACT SIP to EPA by September 15, 2006. This includes areas regulated 

by the Antelope Valley, El Dorado, Feather River, Mojave, Placer, Sacramento, San Joaquin 

Valley, South Coast, Ventura and Yolo Solano APCDIAQMDs. Subpart 1 areas requesting an 

attainment date extension beyond 2009 must submit a RACT SIP at the time of the extension 

request. We expect this will require demonstrations for Amador, Calaveras, Kern, Mariposa, 

Northern Sierra and Tuolumne APCDs by June 15, 2007. It may also include Butte and San 

Diego. Bay Area and Imperial are classified as subpart 2 marginal and are not required to submit 

RACT SIPs for 8 hour ozone at this time. 

Logistics - RACT SIPs must be submitted to EPA by CARB on behalf of the local agencies and 

must fulfill 40 CFR 51 Appendix V completeness criteria just as all other SIP submittals. This 

includes, for example, discussion of any input received when the draft RACT SIP is released for 

public comment. 

Substance - While we are still working with our colleagues in EPA headquarters and other 

Regions to clarify the details of what constitutes a minimally acceptable RACT SIP submit~al, an 

outline of a possible submittal is summarized below for discussion purposes only. Of course, the 

more rigorous the analysis and aggressive the requirements, the more likely that EPA will be able 

to approve them in a legally defensible manner. Keep in mind that we believestates must 

consider new information that has become available and certify that a 1-hour ozone RACT 

determination, even where controls were required, still represents an appropriate RACT level of 

control for the 8-hour ozone program (70 FR 71655, November 29, 2005). We understand that 

CARB staff intends to help the smaller Districts develop these submittals. 
. Describe efforts to identify all source categories within the District requiring RACT, 

including CTG sources (i.e., covered by an EPA Control Technique Guideline document) 

and major non-CTG sources. 

. Submit negative declarations where there are no facilities (major or minor) within the I 

District subject to a CTG. 

For all categories needing RACT, list the statellocal regulation that implements RACT. It 

may also be helpful to list the date EPA approved these regulations as fulfilling RACT. 

Describe the basis for concluding that the regulations fulfill RACT. Documents useful in 

establishing RACT include CTGs, Alternative Control Technique guidance (ACTs) , 

Maximum Achievable Control Technology (MACT) standards, New Source Performance 

Standards (NSPS), California Suggested Control Measures (SCM) and RACTIBest 

Available Retrofit Control Technology (BARCT) determinations, regulations adopted in 

other Districts, and guidance and rules developed by other state and local agencies. 

. We understand that some Districts may use CAPCOA's September 2003, Potential All 

Feasible Measzires (AFM) Report to help demonstrate RACT. If so, the RACT SIP 

should certify that local regulations are equivalent to AFM, justify the assumption that the 

AFM fulfilled RACT in 2003, and include some sort of certification/demonstration that 

no additional controls have become more reasonably available since then. 

Additional information on RACT requirements may be found in 70 FR 71651 - 71659 

(November 29, 2005). Other information that we may provide in the coming weeks if you think , -% i 

it would be helpful includes: 

. A more exhaustive version of the list that we provided to CAPCOA in December 2005 of 

CTGs, ACTs and related documents that EPA has published regarding specific industries. 

Electronic versions of some of the above EPA documents. 

A list of CTGs. 

Suggested text for negative declarations. 

I hope this information is useful and we look forward to continued work on this issue with 

District and CARB staff in the coming months. I plan to contact you next week to ask the status 

of RACT SIP development in California and to see if there is other assistance EPA can provide 

to help CARB and the Districts fulfill this obligation. If you have any questions in the mean 

time, feel free to contact me (415) 947-41 15 or Stanley Tong at (41 5) 947-4122. 

% 

Sincerely, 

~nd;ew Steckel 

Chief, Rulemaking Office 
I 

cc: Air Pollution Control Officers for Amador, Antelope Valley, Bay Area, Butte, Calaveras, 

El Dorado, Feather River, Imperial, Kern, Mariposa, Mojave, Northern Sierra, Places, 

i,-, Sacramento, San Diego, San Joaquin, South Coast, Tuolumne, Ventura, and Yolo Solano 

Air Pollution Control DistrictsIAir Quality Management Districts. r