UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document (TSD)

for

EPA’s Rulemaking

for the

California State Implementation Plan

Imperial County Air Pollution Control District 

Rule 217 -- Large Confined Animal Facilities (LCAF) Permits Required

Rule 101 -- Definitions

Rule 202 -- Exemptions

November 2016
1

RULE IDENTIFICATION 

Agency Imperial County Air Pollution Control District (ICAPCD)

SIP Approved 

Rules

Rule 101 – Definitions

Adopted October 22, 2013

Submitted –February 10, 2014

Approved – October 2, 2014 (79 FR 59433)

Rule 202 – Exemptions

Adopted – October 10, 2006

Submitted – August 24, 2007

Approved –May 9, 2011 (76 FR 26615)

Subject of this TSD Rule 217 – Large Confined Animal Facilities (LCAF) Permits Required

Rule 101 – Definitions

Rule 202 – Exemptions

Amended – February 9, 2016

Submitted – April 21, 2016

Completeness 

Finding

Determination of Completeness letter: May 18, 2016

BACKGROUND 

Imperial County Air Pollution Control District (“ICAPCD” or “District”) regulates the Imperial County portion of 

the Salton Sea Air Basin. Imperial County is classified as moderate nonattainment for the 2006 particulate matter 

less than 2.5 microns in diameter (PM2.5) National Ambient Air Quality Standard (NAAQS), for the 2012 PM2.5

NAAQS, for the 1997 8-hour ozone NAAQS, for the 2008 8-hour ozone NAAQS and serious nonattainment for 

the 1987 PM10 NAAQS (see 40 CFR part 81). 

The Clean Air Act (CAA) requires that for areas classified as moderate or above nonattainment, the State must 

submit provisions to the State Implementation Plan (SIP) to require implementation of reasonably available 

control technology (RACT) (see sections 182(b)(2) and 182(f)). 

Historically, agricultural operations had been exempted from many regulatory requirements, including the need 

for air pollution permits. On September 22, 2003, California Senate Bill 700 (SB 700) became law and removed 

the blanket permitting exemption for agricultural sources provided under California Health & Safety Code 

(CH&SC) Section 42310(e) and subjected large agricultural sources to various permit requirements for the first 

time.

ICAPCD adopted an earlier version of Rule 217 on October 10, 2006 and submitted it to the EPA for approval on 

August 24, 2007. The District requested that CARB withdraw this rule from the SIP on May 3, 2011, and CARB 

withdrew the rule on May 17, 2011.

1 According to the ICAPCD staff report for IC 217 (staff report), Imperial 

County has mainly two types of large confined animal facilities (LCAFs): Beef operations (26) and Dairy 

operations (one).

2

ICAPCD adopted an earlier version of Rule 101-Definitions on October 22, 2013, which was approved into the 

SIP on October 2, 2014 (79 FR 59433). Rule 101 contains definitions for specific terms applicable to all District 

 1 Letter from Robert D. Fletcher, Deputy Executive Officer, CARB, to Jared Blumenfeld, Regional Administrator, EPA, 

dated May 17, 2011. We note that in this letter, CARB states the District requested withdrawal on May 3, 2011, not May 3, 

2013, as stated in Staff Report at page 3. 

2 Staff Report, Appendix A, at page 1.
2

rules. 

ICAPCD adopted an earlier version of Rule 202 – Exemptions on October 10, 2006, which the EPA approved 

into the SIP on May 9, 2011 (76 FR 26615). Rule 202 identifies processes, articles, machines, equipment or other 

contrivances for which an Authority to Construct (ATC) or Permit to Operate (PTO) is not required.

RULE SUMMARY 

Rule 217 is designed to limit volatile organic compound (VOC) and ammonia emissions from large dairies and 

beef feedlots, and other confined animal facilities such as poultry houses and swine facilities. The rule applies to 

operations above size thresholds described in Table 1 of the rule (e.g., 3,500 beef cattle, 500 milking cows). These 

operations must obtain an ICAPCD permit (see section C.1), submit an Emissions Mitigation Plan (EMP) as part 

of the permit (section C.4 and C.5) and implement the mandatory and additional control measures the facility 

chooses from Tables 2.1-2.6, as appropriate. Operations that are not dairy, beef feedlot, swine or poultry 

operations must submit an EMP demonstrating facility-wide reductions of at least 30% or submit an EMP that 

adheres to section C.5. Sections C.3 and D-J describe temporary suspension of mitigation measures, exemptions 

and additional requirements concerning permitting, recordkeeping, testing and monitoring. Operations not 

meeting the LCAF thresholds defined in Table 1 are exempt from rule requirements except for section F. 

Administrative Requirements.

The District estimates VOC emission reductions of 6.9 tons per year (tpy) for dairies and 452.7 tpy for beef 

feedlots.3 The staff report does not estimate ammonia reduction from the rule, but states that in general, the most

ammonia emissions are associated with land application of manure and housing, with significant emissions from 

manure storage and grazing.4

The District amended Rule 101 and Rule 202 to be consistent with Rule 217’s definition of Large CAF. 

Specifically, the District partially revised the Rule 101 definition for “Large Confined Animal Facility (LCAF)”

as a CAF containing 500 or more milk-producing cows (reduced from 1,000), or 400,000 or more chickens or 

ducks (reduced from 650,000).The District made no other changes to Rule 101.

The District amended Rule 202, section E.10.b to change the thresholds for exempting confined animal facilities5

as follows: Maintain less than 500 milk producing cows (reduced from 1,000), less than 400,000 chickens or 

ducks (reduced from 650,000). The District made no other changes to Rule 202.

EVALUATION CRITERIA - The following criteria were used to evaluate the submitted rule. 

1. Enforceability - The Bluebook (Issues Relating to VOC Regulation Cutpoints, Deficiencies, and 

Deviations, EPA, May 25, 1988) and the Little Bluebook (Guidance Document for Correcting Common 

VOC & Other Rule Deficiencies, EPA Region 9, August 21, 2001) were used to help evaluate compliance 

with the CAA §110(a)(2)(A) requirement for enforceability. 

 3 Staff Report at page 5.

4 Id. at page 4. 5 Confined Animal Facility is defined in Rule 101 as follows: “A Source or group of Sources of air pollution at an 

Agricultural Source for the raising of fowl or animals, including but not limited to, any structure, building, installation, farm, 

corral, coop, feed storage area, milking parlor, or system for the collection, storage, or distribution of solid and liquid 

manure; if domesticated animals, including but not limited to, cattle, calves, horses, sheep, goats, swine, rabbits, chickens, 

turkeys, or ducks corralled, penned, or otherwise caused to remain in restricted areas for commercial agricultural purposes 

and feeding is by means other than grazing.”
3

2. Stringency –Nonattainment areas are required to demonstrate reasonably available control measures 

(RACM), including reasonably available control technology (RACT). CAA Section 172(c)(1) requires that 

each attainment plan “provide for the implementation of all reasonably available control measures as 

expeditiously as practicable (including such reductions in emissions from existing sources in the area as 

may be obtained through the adoption, at a minimum, of reasonably available control technology), and 

shall provide for the attainment of the national primary ambient air quality standards.” RACM findings are 

generally made in context of an overall attainment demonstration. Here, we are evaluating whether this 

rule implements RACT-level controls for this area source category to facilitate RACM evaluations in 

future plan evaluations. 

3. SIP Relaxation - CAA §110(l) prohibits the EPA from approving any SIP revision that would interfere with any 

applicable requirement concerning attainment and RFP or any other applicable requirement of the CAA. In 

addition, CAA §193 restricts the modification of any SIP-approved control requirement in effect before November 

15, 1990, in a nonattainment area.

EPA EVALUATION - A summary of our evaluation of the three criteria follows.

1. Enforceability Evaluation - To help ensure enforceability, the rule requirements and applicability are clear, 

and the monitoring, recordkeeping, reporting and other provisions sufficiently ensure that affected sources 

and regulators can evaluate and determine compliance with Rule 217, Rule 101 and Rule 202 consistently.

2. Stringency Evaluation - We are evaluating whether Rule 217 implements RACT-level controls for this 

source category to facilitate RACM evaluations in future plan evaluation. Rules 101 and 202 are 

administrative rules, which are not subject to RACM. In evaluating Rule 217, we compared it to all the 

rules we are aware of that regulate VOC and/or ammonia emissions from CAFs. However, the discussion 

below focusses on four rules: San Joaquin Valley Air Pollution District (SJVAPCD or SJV) Rule 4570, 

South Coast Air Quality Management Rule (SCAQMD) 223, SCAQMD Rule 1127 and the Idaho

Department of Environmental Quality’s (IDEQ) dairy ammonia permit by rule (Idaho dairy rule). 6

Rule 217 is a menu-based rule that was modelled after SJV Rule 4570 and, for the most part, Rule 217 

contains the same applicability, permit requirements, mitigation measures, recordkeeping, monitoring and 

reporting provisions as SJV Rule 4570. On January 17, 2012, the EPA approved Rule 4570 as having 

RACT-level controls for large CAFs (77 FR 2228).

In Rule 217, the thresholds in Table 1 that define large CAF by livestock category are the same or more 

stringent than SJV Rule 4570.7 Both Rule 217 and Rule 4570 require an owner/operator to obtain an 

“authority to construct” or “permit to operate” for the facility, and require the owner/operator to submit a 

facility emission management plan as part of the permit. Both rules require that the permit include the

maximum capacity of the facility and any other information necessary for the District to prepare an 

emissions inventory of the regulated pollutants emitted from the facility. 

 6 SJVAPCD Rule 4570 Confined Animal Facilities, adopted October 21, 2010, approved January 17, 2012 (77 FR 2228), 

SCAQMD Rule 223 Emissions Reduction Permits for Large Confined Animal Facilities, adopted June 2, 2006, approved 

July 13, 2015 (80 FR 39966); SCAQMD Rule 1127 Emission Reductions from Livestock Waste, adopted August 6, 2004, 

approved May 23, 2013 (78 FR 30768); Idaho Administrative Procedure Act (IDAPA) 58.01.01 Sections 760-764: Rules for 

the Control of Ammonia from Dairy Farms (adopted March 30, 2007; amended May 8, 2009). Other CAF rules we are aware 

of include Bay Area AQMD Rule 2-10, Sacramento Metro AQMD Rule 496, Ventura County APCD Rule 23, and Butte 

County Rule 450, but they are significantly less stringent than the rules discussed in this TSD, and therefore are not included 

in the detailed comparison. 7 Rule 217 “other cattle, heifers and calves” threshold is 3,500, as compared to 7,500 in Rule 4570. Rule 217 threshold for 

“horses” is 2,500, as compared to 3,000 in Rule 4570. 
4

The menu requirements for Rule 217 and Rule 4570 are the same, as indicated in Tables 1 and 2. In 

addition, the mitigation measures in within each menu are the same.8

Table 1 – Beef Feedlot Menus

Menus Rule 217 Beef Feedlot Rule 4570 Beef Feedlot

A. Feed At least 2 of 4 measures At least 2 of 4 measures

B. Silage At least 1 of 3 measures At least 1 of 3 measures

C. Housing 4 specific measures and at least 1 of 

3 additional measures

4 specific measures and at least 1 of 

3 additional measures

D. Solid Manure/Separated 

Solids

At least 1 of 2 measures At least 1 of 2 measures

E. Liquid Manure At least 1 of 5 measures At least 1 of 5 measures

F.1. Land Application 

(solid manure)

At least 1 of 4 measures At least 1 of 4 measures

F.1. Land Application

(liquid manure)

At least 1 of 4 measures At least 1 of 4 measures

Sources: ICAPCD Rule 217, Table 2.1 “Beef Feedlot Mitigation Measures Requirements” and SJVAPCD 

Rule 4570 Table 4.2 “Beef Feedlot Phase II Mitigation Measure Requirements.”

Table 2 – Dairy CAF Menus

Menus Rule 217 Dairy Rule 4570 Dairy

A. Silage 4 specific measures and at least 1 of 

4 additional measures

4 specific measures and at least 1 of 

4 additional measures

B. Silage At least 1 of 3 measures At least 1 of 3 measures

C. Milking Parlor At least 1 of 2 measures At least 1 of 2 measures

D. Freestall Barn 2 specific measures and at least 1 of 

4 additional measures

2 specific measures and at least 1 of 

4 additional measures

E. Corrals 6 specific measures and at least 1 of 

4 additional measures

6 specific measures and at least 1 of 

4 additional measures

F. Solid Manure/Separated 

Solids

At least 1 of 3 measures At least 1 of measures

G. Liquid Manure At least 1 of 5 measures At least 1 of 5 measures

H.1 Land Application (solid) At least 1 of 4 measures At least 1 of 4 measures

H.2 Land Application 

(liquid)

At least 1 of 4 measures At least 1 of 4 measures

Sources: ICAPCD Rule 217, Table 2.2 “Dairy CAF Mitigation Measures Requirements” and SJVAPCD 

Rule 4570 Table 4.1 “Dairy CAF Phase II Mitigation Measure Requirements.”

There are a few differences between the rules. Rule 217 requires the owner/operator of any LCAF to 

implement all emission mitigation measures as contained in the permit application on the day that 

operation of an LCAF commences (section C.1.e.). In contrast, SJV Rule 4570 allows 365 days from the 

 8 In addition, the menus and measures in both rules for the “Other Cattle,” “Swine,” “Layer” and “Broiler, Duck or Turkey” 

Mitigation Measure Requirements are the same. We note that Rule 217 Table 2.6 “Broiler, Duck or Turkey Mitigation 

Measure Requirements” erroneously repeats section A.1.b. This should be corrected the next time the rule is revised.
5

date of permit issuance to implement emission mitigation measures, as contained the permit application 

(section 5.3). Both rules provide for a temporary suspension of mitigation measures based on a 

determination by an expert (e.g., licensed veterinarian) that the measure being suspended is detrimental to 

animal health or necessary for the animal to molt, and require that that the owner/operator notify the 

District with 48-hours of that determination.

9 However, Rule 4570, unlike Rule 217, requires that the 48-

hour notice include the specific health condition requiring the mitigation measure to be suspended, and the 

duration that the measure must be suspended for animal health reasons. In addition, Rule 4570 states that 

the measure cannot be suspended for longer than recommended by the expert for animal health reasons, 

while Rule 217 does not. The records retention requirement in Rule 217 is two years for non-major sources 

and five years for major sources, while Rule 4570 requires five years for all sources.

Despite these differences, we believe that, on balance, the rules are equivalent. Therefore, we find that the 

submitted Rule 217 is as stringent as Rule 4570.

SCAQMD Rule 1127, along with Rule 223, regulate emissions from livestock waste at dairy farms

(including heifer and calf farms).

10 SCAQMD Rule 223 was developed contemporaneously with 

SJVUAPCD Rule 4570 (adopted June 2 and June 15, 2006 respectively). Rule 223 requirements are very 

similar to Rule 4570 as the SJVUAPCD originally adopted it in 2006; however, SJVUAPCD revised Rule 

4570 in October 2010 to increase its overall stringency. We consider Rule 4570 to be overall more 

stringent than Rule 223. Based on our finding that Rule 217 is as stringent as Rule 4570, we consider that 

Rule 217 is more stringent than Rule 223. 

Certain provisions in Rule 1127 are more stringent than Rule 217’s dairy provisions. For example, Rule 

1127 section (d) requires dairy CAF operators to pave feedlanes on the corral side of the feedlane fence 8 

feet, while Rule 217 Table 2.2 section E.1. requires operators to pave 8 feet for milk and dry cows, but 

only 6 feet for heifers. Rule 1127 requires dairy operators to clear accumulated manure in excess of 3 

inches in height in each corral at least 4 times per year with at least 60 days between cleaning, while Rule 

217 Table 2.2 section E.2. requires operators to either clean manure from corrals 4 times a year with at 

least 60 days between cleaning, or clean corrals at least once between April and July and at least once 

between September and December, which appears to be less stringent. In other respects, Rule 217 is more 

specific and enforceable than Rule 1127. For example, Rule 1127 section (d) requires that operators 

minimize excess water, in part, by “identifying and eliminating water leaks from trough and trough 

piping,” while Rule 217 Table 2.2 E. Corrals specifies that operators inspect for and repair leaks at least 

once every 7 days. Also, Rule 217, unlike Rule 1127 (or Rule 223) mandates measures for cleaning and 

management of concrete lanes and mandates specific requirements for installing or maintaining shade 

structures. Overall, we find that, on balance, Rules 1127 and 223, in combination, are not more stringent 

than Rule 217. We note that Rule 1127 does not apply to beef feedlots, which are far more prevalent than 

dairy CAFs in the ICAPCD.11

We also compared Rule 217 to the Idaho dairy rule. The Idaho dairy rule requires dairy farms above 

specified threshold numbers of cows or animal units to register with Idaho DEQ and to implement industry 

best management practices (BMPs) to control ammonia emissions. A list of BMPs is contained in the rule. 

Each BMP is assigned a point value based on relative effectiveness in reducing ammonia. Dairy farms must 

employ BMPs totaling 27 points. We note that the points do not correspond to a specific amount of 

ammonia reductions, but rather the relative effectiveness of the BMPs for Idaho dairies. The rule does not 

 9 See Rule 217 section C.3. and Rule 4570 section 5.4. 10 Rule 1127 also regulates manure processing operations, which is outside the scope of Rule 217. 11 According to the Rule 217 Staff Report Appendix A, there are 26 beef feedlots and one dairy under the ICAPCD 

jurisdiction. The ICAPCD estimates that dairies emit 0.08 tpd of uncontrolled VOC, while beef feedlots emit 5.39 tpd, or 

98.5% of total uncontrolled VOC. See Rule 217 Staff Report, Table 3. 
6

mandate a specific level of reductions. However, the Idaho dairy rule supporting documentation states that 

“...a practice receiving 20 points would equate to a system or practice that would result in a major 

reduction, approximately 70 percent, in ammonia emissions for that specific process.”12

Since the Idaho rule is based on a point system and Rule 217 is based on implementing a specific number 

of mitigation measures for different components of the CAF operation, 13 it is difficult to compare the

requirements in these two rules directly. Both rules contain options for controlling ammonia emissions in 

different parts of the CAF operation, but Rule 217 is more prescriptive in requiring a certain number of 

BMPs for each component, while the Idaho rule does not set a specific number of BMPs and instead

requires that the points associated with the selected BMPs total at least 27. It is not clear whether practices 

accumulating 27 points would be more or less effective than implementation of measures in Rule 217, 

especially when considering the differences in climate and geography between Imperial County and the 

state of Idaho. 

In some respects, Rule 217 has more stringent provisions than the Idaho rule (e.g., rule applicability

threshold, and provisions for temporary suspension/substitution, testing and records retention). Rule 217 

applies not only to dairies, but to beef feedlot, swine, poultry and other CAFs. On the other hand, the Idaho

rule contains options (e.g., chemical amendments, lagoon nitrification/de-nitrification systems, lagoon

covers, tunnel ventilation with biofilter, and incorporation of manure within 24 hours of land application)

that are not specifically listed as options in Rule 217.

14 However, it is not clear whether these control

options are commonly implemented in Idaho or reasonably available or appropriate for use in Imperial 

County. Therefore, we have no basis to conclude that the Idaho dairy rule is more or less stringent than 

Rule 217.

We are aware of no Control Techniques Guideline (CTG), New Source Performance Standard (NSPS),

National Emission Standard for Hazardous Air Pollutants (NESHAP), or other national regulation or 

guidance that could help define RACT specifically for CAF operations. Similarly, we are aware of no 

Suggested Control Measure (SCM), Best Available Retrofit Control Technology (BARCT) assessment, or 

other State regulation or guidance that could help define RACT specifically for CAF operations. As 

discussed above, we are aware of only eight rules adopted anywhere in the country for VOC or ammonia 

control from CAF operations. Of these, Imperial Rule 217 is clearly more stringent than five (SCAQMD 

Rule 223, Bay Area AQMD Rule 2-10, Sacramento Metro AQMD Rule 496, Ventura County 

APCD Rule 23 and Butte County Rule 450) and very similar to one (SJVAPCD Rule 4570). The 

remaining two rules (SCAQMD Rule 1127 and Idaho 58.01.01) are more stringent in some respects 

and less stringent in other respects than ICAPCD Rule 217, but it is not obvious that ICAPCD is 

less on balance. As a result, we believe that the submitted rule implements RACT-level controls for 

VOC and ammonia. 

3. We propose to determine that our approval of the submittal would comply with CAA §§110(l) and 193 

because (1) the proposed SIP revision would not interfere with the on-going process for ensuring that 

requirements for RFP and attainment of the NAAQS are met, and (2) the emission limits in the submitted 

rule are more stringent than the existing SIP-approved control requirements that they would replace.

 12 Scientific Basis for the Control of Ammonia from Dairy Farms Best Management Practices, Idaho Department of 

Environmental Quality, July 18, 2006. 

13 For example, see Table 2.2 section E. Corrals: “An owner/operator of a dairy CAF shall implement mitigation measures 

1,2,3, 4, 5, and 6 and at least one (1) additional mitigation measure in each corral where animals have been housed in the last 

thirty (30) days...”

14 Rule 217 allows for implementation of an alternative mitigation measure(s), not listed.
7

ADDITIONAL RECOMMENDATIONS FOR THE NEXT RULE REVISION - The following revisions are 

not currently the basis for rule disapproval, but are recommended for the next time the rules are amended. 

1. Rule 217 - Please define undefined terms: Biofilter, Feedlane, Leachate. Please delete B.38 “Overall 

Capture and Control,” as it is neither defined nor used in the rule. 

2. Rule 217 - We recommend that Rule 217 require, per SJV Rule 4550 section 5.4, that the 48 hour 

notification to the District include the specific health condition requiring the mitigation measure to be 

suspended; and the duration that the measure must be suspended for animal health reasons. 

3. Rule 217 - We recommend that Section J. Recordkeeping require all facilities to maintain records for five 

years instead of two years.

4. Rule 217 –Table 2.6 “Broiler, Duck or Turkey Mitigation Measure Requirements, section A.1.a. Delete 

the text “orb. Feed animal probiotics designed to improve digestion according to manufacturer 

recommendations” as it is duplicative of A.1.b. 

5. Rule 10115 - The definition, “Federal Lan Manager” contains a typographical error. “Lan” should be 

“Land.” 

6. Rule 101 - The term, “Mobile Source Emission Reduction Credit” should be deleted from the definition 

“Banking” because it creates a name for the bank not the credit system. 

7. Rule 101 - The definition, “Certificate” has the wording “ERC/MSERC/ABERC” within it describing the 

three kinds of credits. These acronyms should be spelled out.

8. Rule 202 Section E.10.a - For clarity and enforcement the term “stationary combustion agricultural 

sources” should be defined in Rule 202 or the term should be changed to use the term already defined in 

Rule 101 – Definitions, Agricultural Source. The Rule 101 definition of this term includes an exclusion 

for engines used to propel implements of husbandry, which is not clearly identified as part of the 

exemption for stationary combustion agricultural sources (E.10.a), since this term is not defined. 

EPA ACTION

The submitted Rules 217, 101 and 202 strengthen the SIP, and the associated District staff report projects Rule 

217 will reduce VOC emissions by 459.6 tpy. The rule largely fulfils the relevant CAA §110 and part D 

requirements. Therefore, EPA staff recommends approval of Rules 217, 101 and 202 pursuant to CAA §110(k)(3) 

and §301(a). 

REFERENCES

1. “Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations,” (a.k.a., Bluebook) EPA 

OAQPS, May 25, 1988.

2. “Guidance Document for Correcting Common VOC & Other Rule Deficiencies,” (a.k.a., Little 

Bluebook), EPA Region 9, August 21, 2001.

3. ICAPCD Rule 217 – Large Confined Animal Facilities (LCAF) Permits Required Amended February 9, 

2016; Submitted April 21, 2016.

4. ICAPCD Rule 101 – Definitions, Amended February 9, 2016; Submitted April 21, 2016.

5. ICAPCD Rule 217 – Exemptions, Amended February 9, 2016; Submitted April 21, 2016.

 15 Recommendations #4-7 are copied from our TSDs for the prior SIP approvals of Rules 101 and 202. See United States 

Environmental Protection Agency Region IX Air Division Technical Support Document for EPA’s Direct Final Rulemaking 

for the California State Implementation Plan, Imperial County Air Pollution Control District, Rule 101, Definitions, USEPA, 

May 2014; United States Environmental Protection Agency Region IX Air Division Technical Support Document for EPA’s 

Notice of Proposed Rulemaking for the California State Implementation Plan as submitted by the California Air Resources 

Board EPA’s Analysis of Imperial County Air Pollution Control District’s Rule 201, Permits Required Rule 202, 

Exemptions, January 2011. EPA has not performed a comprehensive review of Rules 101 and 202 since then, and this TSD 

largely evaluates the rule revisions regarding CAFs adopted on February 9, 2016.
8

6. Staff Report, ICAPCD Rule 217 – Large Confined Animal Facilities (LCAF) Permits Required Amended 

February 9, 2016; Submitted April 21, 2016.

7. United States Environmental Protection Agency Region IX Air Division Technical Support Document for 

EPA’s Direct Final Rulemaking for the California State Implementation Plan, Imperial County Air 

Pollution Control District, Rule 101, Definitions, USEPA, May 2014.

8. United States Environmental Protection Agency Region IX Air Division Technical Support Document for 

EPA’s Notice of Proposed Rulemaking for the California State Implementation Plan as submitted by the 

California Air Resources Board EPA’s Analysis of Imperial County Air Pollution Control District’s Rule 

201, Permits Required Rule 202, Exemptions, January 2011.