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 recognizethat some details of the requirementremain 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 SolanoAPCDIAQMDs. Subpart 1areas 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 8hour 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 Vcompleteness criteriajust as all other SIP submittals. This includes, for example,discussion of any input received when the draft RACT SIPis 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 aggressivethe requirements, the more likely that EPA will be able to approvethem in a legally defensible manner. Keep in mind that we believestates must consider new information that has become available and certify that a 1-hourozone RACT determination,even where controls were required, still represents an appropriate RACT level of control for the 8-hour ozone program (70FR 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 forconcluding that the regulations fulfill RACT. Documents useful in establishing RACT include CTGs,Alternative Control Technique guidance (ACTs) , Maximum Achievable Control Technology (MACT) standards, New SourcePerformance 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,

### PotentialAll 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 70FR 71651 - 71659 (November29, 2005). Other information that we may provide 

### in the coming weeks if you think , -% i itwould 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 aboveEPA documents. A list of CTGs. Suggested text for negative declarations. Ihope this information is useful and we look forward to continued work on this issue with District and CARB staffin the comingmonths. Iplan 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 (415)947-4122. % Sincerely,

~nd;ewSteckel Chief, Rulemaking OfficeI cc: 

### Air Pollution Control Officers forAmador, Antelope Valley,Bay Area, Butte,Calaveras, El Dorado, Feather River, Imperial, Kern, Mariposa,Mojave,Northern Sierra,Places, i, -, 

### Sacramento, San Diego, San Joaquin, SouthCoast, Tuolumne, Ventura, and Yolo Solano Air Pollution Control DistrictsIAir Quality Management Districts. r