United States Environmental Protection Agency, Region 9

Air Division

Technical Support Document

for

EPA’s Notice of Proposed Rulemaking

for the

California State Implementation Plan

Santa Barbara County Air Pollution Control District’s

Rule 352, Natural Gas-Fire Fan-Type Central Furnaces and Small Water Heaters

Prepared by: Idalia Pérez

October 2012
Santa Barbara County Air Pollution Control District (SBCAPCD)

Submitted Rule

SBCAPCD Rule 352, Natural Gas-Fire Fan-Type Central Furnaces and Small Water Heaters

 Revised: October 20, 2011

 Submitted: February 23, 2012

 Determined complete: March 13, 2012

Previous Rule Submittals

There are no outstanding submittals of Rule 352.

SIP-Approved Rule

 Adopted: September 16, 1999

 Approved by EPA: December 20, 2000 (65 FR 79752)

Rule Summary

Rule 352 limits NOx emissions from gas-fired fan-type central furnaces and small water heaters. 

Rule Amendments 

Rule 352 was amended to expand the applicability of the rule to include all small water heaters 

and strengthen the emission limits for NOx.

Section E was amended to allow certification only from the South Coast Air Quality 

Management District (SCAQMD) in lieu of testing.

Other changes were made to improve consistency, clarity and enforceability of rule 352. 

Effects on Emissions

The staff report indicates that Rule 352 will lead to an approximate reduction of 0.0867 tons of 

NOx per day in 2020.

Rule Evaluation Criteria 

We have evaluated Rule 352 in accordance with the following criteria:

1. Rule Stringency – Generally, SIP rules must be enforceable (see section 110(a) 

of the Clean Air Act, hereafter CAA); must require Reasonably Available Control 

Technology (RACT) for major sources in nonattainment areas (see CAA 

§182(b)(2) and (f)). Santa Barbara County is designated as 

unclassifiable/attainment for all National Ambient Air Quality Standards 

(NAAQS) thus, submitted Rule 352 does not have to fulfill RACT requirements

and we are not evaluating the stringency of the NOx emission limit in Rule 352.

2. Enforceability – CAA section 110(a)(2)(A) requires that regulations submitted to 

EPA for approval into a State Implementation Plan (SIP) be clear and legally 

enforceable. 
3. SIP Revisions - CAA section 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. In addition, CAA section 193 prohibits the modification 

of any SIP-approved control requirement in effect before November 15, 1990, in a 

nonattainment area.

Guidance and policy documents that we used to evaluate Rule 352 include the following:

 Issues Relating to VOC Regulation, Cutpoints, Deficiencies, and Deviations (the "Blue 

Book"), US EPA, OAQPS (May 25, 1988).

 Guidance Document for Correcting Common VOC and Other Rule Deficiencies, EPA 

Region IX (August 21, 2001, the “Little Bluebook”).

Recordkeeping and other compliance provisions in the rule ensure that the requirements are 

adequately enforceable. The expanded applicability and the addition of more stringent NOx

emission limits make the amendments a strengthening of the SIP. Thus, approval of the 

submitted rule does not relax the SIP and satisfies CAA §110(l) and §193. 

Suggested Rule Improvements

SCAQMD Rule 1111, amended on November 6, 2009, has more stringent limits for furnaces. 

The SBCAPCD should consider including these limits the next time the rule is amended. 

Recommendation

EPA staff recommends direct final approval of SBCAPCD submitted rule 352 for incorporation 

into the California SIP.

Other References

1. SIP-approved version of Rule 352

2. Submitted Rule 352

3. Submittal package for Rule 352