UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION IX AIR DIVISION

Technical Support Document 

for

EPA’s Rulemaking for the California State

Implementation Plan

regarding

Placer County Air Pollution Control District

Rule 515, “Stationary Rail Yard Control Emission 

Reduction Credits”

Prepared by: Nancy Levin

September 4, 2015
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RULE IDENTIFICATION

Agency: Placer County Air Pollution Control District

(PCAPCD)

Current SIP Approved Rule: None

Prior Submittal/Withdrawal: Rule 515 “Stationary Rail Yard Control Emission 

Reduction Credits”

Adopted: October 9, 2008

Submitted: December 23, 2008

Withdrawn: August 11, 2014

Submittal Subject to this TSD: Rule 515 “Stationary Rail Yard Control Emission 

Reduction Credits”

Adopted: February 19, 2015

Submitted: June 26, 2015

Completeness Determination: August 13, 2015

BACKGROUND:

Under Section 107(d) of the Clean Air Act (CAA), EPA has designated Placer County 

(partial) nonattainment for the following three National Ambient Air Quality Standards 

(NAAQS): 1-hour ozone, 1997 8-hour ozone, and 2006 PM2.5. This area is regulated by 

the Placer County Air Pollution Control District (PCAPCD). New or modified major 

stationary sources subject to PCAPCD’s Federal New Source Review (NSR) program 

must obtain emission reductions to offset emission increases prior to constructing such 

sources.

1 The purpose of Rule 515 is to provide owners or operators of a rail yard a 

mechanism for quantifying, certifying, and banking emission reduction credits (ERC) 

from the installation and use of a control device that reduces emissions from locomotive 

engines in rail yards. There is currently one rail yard in the District, the Union Pacific 

J.R. Davis Yard. Approval of Rule 515 into the SIP would allow these ERCs to be used 

as offsets under PCAPCD's New Source Review (NSR) rule.2 Existing PCAPCD Rule 

504 “Emission Reduction Credits” (Adopted 9-21-93, Amended 11-03-94, 8-12-10) 

governs the banking and transfer of ERCs, and Rule 502 “New Source Review” governs 

the use of ERCs. These two rules are not the subject of this rulemaking action.

 1 Rule 502 New Source Review (Adopted 11-12-74, Amended 05-24-77, 06-19-79, 09-21-93, 11-03-94, 08-

09-01, 12-09-04, rescinded and re-adopted 2-11-10, amended 10-13-11) has been approved into the SIP 

(September 24, 2013, 78 FR 58460). Rule 502 requires the use of federally enforceable Emission Reduction

Credits (ERCs). Rule 515, if approved, would provide for the generation of federally enforceable ERCs. 2 Rule 515 would provide for the generation of federally enforceable ERCs to address more stringent state 

offset requirements for pollutants such as PM10 and CO, even though PCAPCD is in federal attainment for 

PM10 and CO. See Attachment 3.
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RULE SUMMARY:

Rule 515 establishes standards, the administrative process, and enforceable procedures 

for calculating creditable emission reductions of volatile organic compounds (VOC), 

nitrogen oxides (NOx), carbon monoxide (CO), particulate matter of 10 microns or less 

(PM10), and sulfur oxides (SOx) created through the installation and use of a control 

device for locomotive engines in rail yards. Once an ERC certificate has been issued by 

the Air Pollution Control Officer (APCO), the ERCs may be used as offsets to meet 

federal or state NSR requirements.

Under Rule 515, owners or operators of rail yards are eligible to apply for ERCs if 

they install stationary emission control equipment in rail yards or other locations 

where locomotive diesel engines may be running while the locomotive remains 

stationary in a defined location. They must first obtain a permit that includes 

enforceable conditions to ensure compliance with the specific rule requirements. Rule 

515 specifies that actual emission reductions must be real, surplus, enforceable, 

permanent, and quantifiable. Continuous monitors must be used to measure inlet and 

outlet emissions of the control device to determine the amount of emissions reduced. 

The rule prohibits PM10 and/or PM2.5 ERCs from being used to provide offsets for 

diesel particulate matter.

Owners and operators are subject to monitoring, testing, recordkeeping, and reporting 

requirements. (See section 500). Applicants must provide an analysis of historical 

locomotive activity to support emission calculations, and a “reasonable expectation 

that a specific amount of emission reductions can be achieved on an on-going basis, 

taking into account lower than expected activity level, and other factors.” (See 

section 401.3). Applicants must also take into account expected future emission 

reductions as the fleet is upgraded with lower-pollutant emitting locomotives. (See 

section 401.4). 

EPA REVIEW CRITERIA: 

EPA generally considers three criteria in evaluating state and local prohibitory rules for

approval into the SIP. For this rulemaking, we are considering two additional criteria.

1. Enforceability - Section 110(a) of the CAA requires enforceable SIP requirements.

Several EPA guidance documents are used to evaluate rule enforceability, 

including the “Bluebook” (Issues Relating to VOC Regulation Cutpoints, 

Deficiencies, and Clarification to Appendix D, November 24, 1978, 52 FR 45044) 

and EPA Region IX’s Guidance Document for Correcting Common VOC and 

Other Rule Deficiencies (August 21, 2001, the “Little Bluebook”).

2. Non-interference - CAA §110(l) prohibits EPA from approving any SIP revision 

that would interfere with any applicable requirement concerning attainment and 

reasonable further progress (RFP) or any other applicable requirement of the CAA. 
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In addition, CAA §193 prohibits the modification of any SIP-approved control 

requirement in effect before November 15, 1990, in a nonattainment area.

3. Stringency - Section 182(b)(2) of the CAA requires certain SIP rules to apply 

Reasonably Available Control Technology (RACT). Other sections of the Act 

require other control levels.

4. New Source Review – Section 173(c) of the CAA and 40 CFR Part 51, Appendix 

S, “Emission Offset Interpretative Ruling” require certain sources to obtain 

emission reductions to offset increased emissions from new projects.

5. Economic Incentive Programs - EPA published the guidance, “Improving Air

Quality with Economic Incentive Programs” on January 2001 (EPA-452/R-01-

001).This guidance applies to discretionary economic incentive programs (EIPs) 

and represents the agency’s interpretation of what EIPs should contain in order to 

meet the requirements of the CAA. Because this guidance is non-binding and does 

not represent final agency action, EPA is using the guidance as an initial screen to 

determine whether potential approvability issues arise.

EPA EVALUATION: 

Rule 515 complies with the evaluation criteria as discussed briefly below.

1. Enforceability – The applicability and requirements of Rule 515 are generally clear 

and consistent with the Bluebook and other relevant EPA guidance regarding 

enforceability. Rule 515 includes references to other PCAPCD rules. We evaluated 

the referenced rules to determine the purpose of the reference, whether the rules 

were SIP approved, and whether the rules affected the criteria, standards, and 

procedures for generating valid ERCs under Rule 515. We determined that these

references did not affect the approvability of the rule.

2. Non-interference – Rule 515 does not replace any existing rule currently in the 

SIP. In addition, Rule 515 only provides a mechanism to generate credits for 

new emission reductions, and other requirements in Rule 515 and elsewhere 

ensure that these emission reductions are greater than any emission increases 

associated with use of the ERCs. Therefore, approval of this rule will not 

interfere with any applicable requirement concerning attainment and reasonable

further progress (RFP) or any other applicable requirement of the CAA.

3. Stringency – None of these CAA sections apply to Rule 515, so stringency is not 

being used to evaluate SIP approvability.

4. New Source Review – Emission reductions to be used as NSR offsets must be 

surplus, enforceable, quantifiable, and permanent. The surplus criterion
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includes being consistent with the emissions inventory estimates for the 

Roseville Rail Yard in any attainment plan for the area.

Rule 515 meets the quantification criterion because it includes a methodology to 

quantify emissions and emission reductions in Sections 404 (Quantification 

Protocol) and 405 (Emission Reduction Credit Adjustments of Calculated Credits)

that will provide replicable quantification. 

The emission reductions will be permanent and enforceable because the owner of 

the rail yard, who has been issued an ERC under Rule 515, is subject to violations 

for failure to comply with any provision of the rule or any permit condition (See 

section 406.1).

5. Economic Incentive Program - Several fundamental principles described in the 

guidance include integrity (credits are based upon emission reductions which are 

surplus, enforceable, quantifiable, and permanent), equity, and environmental 

benefit. The integrity principle is the same as those described under NSR 

evaluation and described above. This rule generates emissions offsets for the NSR 

program and does not raise any equity issues that are different from the NSR 

program in general. The environmental benefit has been addressed in the required 

offset ratio defined by the NSR program.

EPA ACTION: 

EPA staff recommends full approval of the submitted version of Rule 515 because it

complies with all relevant CAA requirements and is consistent with EPA’s guidance for 

NSR and economic incentive programs.

REFERENCES:

1. “Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations,”

(a.k.a., Bluebook) EPA OAQPS, May 25, 1988 (web citation).

2. “Guidance Document for Correcting Common VOC & Other Rule Deficiencies,”

(a.k.a., Little Bluebook), EPA Region 9, August 21, 2001

(http://www.epa.gov/region09/air/sips/littlebluebook2001.pdf).

ATTACHMENTS:

1. PCAPCD Rule 515, “Stationary Rail Yard Control Emission Reduction Credits,”

adopted on October 9, 2008 and submitted by CARB to EPA on December 23, 

2008.

2. “Improving Air Quality with Economic Incentive Programs,” January 2001, EPA452/R-01-001 (cover only; text at 

http://www.epa.gov/ttncaaa1/t1/meta/m1201.html).
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3. Memo dated September 4, 2015 from Nancy Levin, EPA Rules Office, to 

proposed rulemaking file, “PCAPCD Attainment Status and ERCs.”
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ATTACHMENT 3

MEMORANDUM 

Date: September 4, 2015

Subject: PCAPCD Attainment Status & ERCs

From: Nancy Levin, EPA Region 9 Air Division, Rules Office, AIR-4

To: File for Proposed Rulemaking on PCAPCD Rule 515

If PCAPCD Rule 515 is approved into the SIP, it will provide for the generation of 

federally-enforceable Emission Reduction Credits (ERCs) for VOC, NOx, PM10,

PM2.5, CO, and SOx. PCAPCD’s attainment status varies depending on the pollutant. 

The following describes the area’s current federal attainment status, as well as where and 

how these ERCs can be used. This analysis takes into account the fact that PCAPCD 

may be in federal attainment (e.g., where no offsets are required for federal New Source

Review (NSR)) yet sources in the area may be subject to more stringent state offset 

requirements embedded in the SIP-approved NSR rule. The more stringent state 

requirements are typically implemented by having a lower emissions threshold for

requiring offsets.

VOC and NOx (1-hour and 8-hour Ozone NAAQS)

PCAPCD is classified as federal nonattainment for the 1-hour and 8-hour ozone

NAAQS.

 VOC and NOx are precursors to ozone.

 Therefore, VOC and NOx ERCs can be used for sources located 

within the Placer County ozone nonattainment area or other federal 

nonattainment areas if certain conditions are met.

These VOC and NOx ERCs could also be used to meet more stringent state VOC 

and NOx offset requirements embedded in PCAPCD’s NSR rule.

PM10

 PCAPCD is classified as federal attainment for the PM10 NAAQS.

 Because these PM10 ERCs are being generated in an area that is in federal 

attainment, under the CAA, these PM10 ERCs cannot be used as NSR offsets 

in any federal nonattainment area.

 These PM10 ERCs could be used to meet more stringent state PM10

offset requirements embedded in PCAPCD’s NSR rule or in any other

area in accordance with state law.

PM2.5

 Portions of PCAPCD are classified as federal nonattainment for the PM2.5

NAAQS. Because these PM2.5 ERCs are being generated in an area that is 

federal nonattainment, under the CAA, these PM2.5 ERCs can be used as PM2.5 
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offsets in Placer County or other federal nonattainment areas if certain conditions 

are met.

 These PM2.5 ERCs could also be used to meet more stringent state 

PM2.5 offset requirements embedded in PCAPCD’s NSR rule.

CO

 PCAPCD (and the entire state) is classified as federal attainment for CO.

 The CO ERCs could be used to meet more stringent state offset requirements 

embedded in PCAPCD’s NSR rule or in any other area in accordance with state 

law.

SOX

 PCAPCD is classified as federal attainment for SOx.

 SOX is a precursor to both PM10 and PM2.5.

 Because PCAPCD is in federal attainment for PM10, the SOx ERCs could be

used for more stringent state offset requirements in PCAPCD, but cannot be used 

as PM10 offsets in any federal PM10 nonattainment area.

 Because PCAPCD is a federal nonattainment area for PM2.5, the SOx ERCs

could be used as PM2.5 offsets if the District obtains SIP approval of the

appropriate PM2.5 to SOx interpollutant offset ratios.

NOx

 PCAPCD is classified as federal attainment for NOx.

 NOx is a precursor to PM2.5.

 Because PCAPCD is a federal nonattainment area for PM2.5, the NOx ERCs 

could be used as PM2.5 offsets if the District obtains SIP approval of the

appropriate PM2.5 to NOx interpollutant offset ratios.