CALIFORNIA AIR RESOURCES BOARD 

SIP COMPLETENESS CHECKLIST 

(Electronic Format) 

*** TO BE COMPLETED BY DISTRICT AND RETURNED TO ARB *** 

All rules submitted to the EPA as State Implementation Plan (SIP) revisions must be supported by certain information 

and documentation for the rule packages to be deemed complete for review by the EPA. Rules will not be evaluated for 

approvability by the EPA unless the submittal packages are complete. To assist you in determining that all necessary 

materials are included in rules packages sent to the ARB for submittal to the EPA, please fill out the following form and 

include it with the rule package you send ARB. See the ARB's Guidelines on the Implementation of the 40 CFR 51, 

Appendix V, for a more detailed explanation than is provided here. Adopted rules and rule amendments should be 

checked against U.S. EPA's Guidance Document for Correcting Common VOC & Other Rule Deficiencies (Little Blue 

Book, August 21, 2001) to ensure that they contain no elements which will result in disapproval by EPA. 

District: Ventura County Air Pollution Control District 

Rule No: New Rule 74.31 and Amendments to Rule 23 

Rule Title: Rule 74.31, Metalworking Fluids and Direct Contact Lubricants and Rule 23, Exemptions from Permit 

Date Adopted or Amended: November 12, 2013 

ADMINISTRATIVE MATERIALS 

Note: All documents should be in electronic format. Items that have signatures, initials, or stamps may be scanned. 

 Not 

Attached Attached N/A 

 COMPLETE COPY OF THE RULE: Provide an unmarked copy of the entire 

rule as adopted or amended by your District Board. 

 UNDERLINE AND STRIKEOUT COPY OF THE RULE: If an amended rule, 

provide a complete copy of the rule indicating in underline and strikeout format 

all language which has been added, deleted, or changed since the rule was 

last adopted or amended. 

 COMPLETE COPY OF THE REFERENCED RULE(S): For any rule which 

includes language specifically referencing another rule, a copy of that other 

rule must also be submitted, unless it has already been submitted to EPA as 

part of a previous SIP submittal. 

 PUBLIC NOTICE EVIDENCE: Include a copy of the local newspaper clipping 

certification(s), stating the date of publication, which must be at least 30 days 

before the hearing. As an alternative, include a copy of the actual published 

notice of the public hearing as it appeared in the local newspaper(s). In this 

case, however, enough of the newspaper page must be included to show the 

date of publication. The notice must specifically identify by title and number 

each rule adopted or amended. 

 RESOLUTION/MINUTE ORDER: Provide the Board Clerk certified resolution 

or minute order. This document must include certification that the hearing 

was held in accordance with the information in the public notice. It must also 

list the rules that were adopted or amended, the date of the public hearing, 

and a statement of compliance with California Health and Safety Code 

Sections 40725-40728 (Administrative Procedures Act). 

 PUBLIC COMMENTS AND RESPONSES: Submit copies of written public 

comments made during the notice period and at the public hearing. Also 

submit any written responses prepared by the District staff or presented to the 

District Board at the public hearing. A summary of the public comments and 

responses is adequate. If there were no comments made during the notice 

period or at the hearing, please indicate N/A to the left. 
 

5/1/2002 

CALIFORNIA AIR RESOURCES BOARD 

SIP COMPLETENESS CHECKLIST 

(Electronic Format)

TECHNICAL MATERIALS 

 Not 

Attached Attached N/A 

 RULE EVALUATION FORM: See instructions for completing the Rule 

Evaluation Form and the accompanying sample form. 

 NON-EPA TEST METHODS: Attach all test methods that are referenced in 

your rule that do not appear in 40 CFR 51, 60, 61, 63, or have not been 

previously submitted to EPA. EPA methods used in other media such as 

SW846 for solid waste are not automatically approved for air pollution 

applications. Submittal of test methods that are not EPA-approved should 

include the information and follow the procedure described in Region 9’s “Test 

Method Review & Evaluation Process.” 

 MODELING SUPPORT: Provide if appropriate. In general, modeling support is 

not required for VOC and NOx rules to determine their impacts on ozone 

levels. Modeling is required where a rule is a relaxation that affects large 

sources (> 100 TPY) in an attainment area for SO2, directly emitted PM10, 

CO, or NOx (for NO2 purposes). In cases where EPA is concerned with the 

impact on air quality of rule revisions which relax limits or cause a shift in 

emission patterns in a nonattainment area, a reference back to the approved 

SIP will be sufficient provided the approved SIP accounts for the relaxation 

and provided the approved SIP used the current EPA modeling guidelines. If 

current EPA modeling guidelines were not used, then new modeling may be 

required. 

 ECONOMIC AND TECHNICAL JUSTIFICATION FOR DEVIATIONS FROM 

EPA POLICIES: The District staff report or other information included with the 

submittal should discuss all potential relaxations or deviations from RACT, 

RACM, BACT, BACM, enforceability, attainment, RFP, or other relevant EPA 

requirements. This includes, for example, demonstrating that exemptions or 

emission limits less stringent than the presumptive RACT (e.g., a CTG) meet 

EPA’s 5 percent policy, and demonstrating that all source categories 

exempted from a RACM/BACM rule are de minimus according to EPA’s 

RACM/BACM policy. 

 ADDITIONAL MATERIALS: Provide District staff reports and any other 

supporting information concerning development of the rule or rule changes. 

This information should explain the basis for all limits and thresholds 

contained in the rule.