Technical Support Document 

for 

EPA's Notice of Proposed Rulemaking 

on revisions to the 

California State Implementation Plan 

as submitted by the California Air Resources Board 

for the San Joaquin Valley Air Pollution Control District 

 

EPA's Analysis of 

San Joaquin Valley Air Pollution Control District’s 

Rule 4570, Confined Animal Facilities 

United States Environmental Protection Agency, Region IX 

Air Division 

 

June 2009 
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A. Rule Adoption and Submittal Chronology 

June 18, 2009: The San Joaquin Valley Air Pollution Control District (SJVAPCD) 

Governing Board adopts Rule 4570, Confined Animal Facilities (CAF). 

June 26, 2009: The California Air Resources Board (CARB) submits Rule 4570 to EPA (on 

behalf of SJVAPCD) as a revision to the California State Implementation 

Plan (SIP). 

June 30, 2009: EPA finds the submittal of Rule 4570 complete. 

EPA has not approved a version of Rule 4570 into the SIP. 

B. Rule Summary

Rule 4570 is designed to decrease volatile organic compound (VOC) emissions from dairies, 

beef feedlots, poultry houses, and other confined animal facilities. Most of the rule requirements 

apply only to large operations above size thresholds described in table 1 (e.g., 650,000 chickens). 

These operations must obtain an SJVAPCD permit describing the control measures the facility 

chooses to implement from menus of control measure options listed in tables 2–6. These menus 

were developed partly during a series of public meetings with interested parties. Sections 6–8 

describe additional requirements concerning permitting, recordkeeping, testing and monitoring. 

C. Evaluation Criteria – EPA is using the following criteria to evaluate Rule 4570. 

1. Enforceability - The Bluebook (reference #1) and the Little Bluebook (reference #2) were 

used to help evaluate compliance with the federal Clean Air Act (CAA) Section 110(a)(2)(A) 

requirement for enforceability. 

2. Anti-Backsliding – CAA Section 110(l) states that “[t]he Administrator shall not approve a 

revision of a plan if the revision would interfere with any applicable requirement concerning 

attainment and reasonable further progress, or any other applicable requirement of this chapter.” 

3. RACT – CAA Section 182(b)(2) directs nonattainment areas like SJVAPCD to adopt and 

submit SIP provisions implementing Reasonably Available Control Technology (RACT) for all 

major stationary sources of VOC. RACT is “the lowest emission limitation that a particular 

source (can meet using) control technology that is reasonably available, considering 

technological and economic feasibility.” (44 FR 53762, September 17, 1979). 

SJVAPCD’s RACT-SIP (attachment #3) provides an analysis of RACT implementation in the 

District, partly in response to EPA’s 8-hour Ozone Implementation Guidance (reference #5). It 

includes 71 pages discussing how Rule 4570 implements RACT for CAF operations. We 

categorize that discussion into fourteen elements below, and briefly respond to each. 
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a. We must understand the quantity and speciation of VOC emissions from CAF operations 

before developing cost-effective controls. Because this industry is newly regulated and 

involves complex biological processes, we have limited emissions inventory information. 

(RACT-SIP section 1.2).

EPA Response. Ideally, agencies would have complete knowledge of all relevant factors 

(emissions inventory, control costs, changes in industrial practices, market factors, etc.) 

before developing regulations. In reality, agencies typically develop regulations with 

incomplete knowledge and can subsequently adjust the regulations as new information 

becomes available. 

Significant work has been completed to help understand CAF emissions and available 

controls, including studies by Dr. Frank Mitloehner (U.C. Davis) and Dr. Chuck Schmidt 

(RACT-SIP section 1.2.2). Other studies should finish in the coming months, including 

research funded by the State of Utah, additional dairy-focused work from Dr. Mitloehner, 

and the National Air Emission Monitoring Study (NAEMS), a $14.8 million industry funded 

analysis of CAF emissions at 25 sites nationwide that EPA is overseeing. Monitoring under 

NAEMS began in July 2007 and data collection and analyses should be completed by May 

2010. EPA expects to release emission estimating methodologies based on this work by 

November 2011 or earlier. 

b. Rule 4570 requires emission control of all large units at all CAFs that are major sources. 

(RACT-SIP sections 4.1 and 5). 

EPA Response. Rule 4570 exempts poultry operations with fewer than 650,000 chickens 

from regulation (table 1). The RACT-SIP estimates 0.050 lb/year VOC emissions for each 

chicken laying eggs or “layer” (table 6). Therefore, facilities with 400,000 – 650,000 layers 

appear to be major sources not subject to Rule 4570 requirements. SJVACPD staff believe 

that three such facilities exist.1

c. There are no federal rules or guidance for CAFs (e.g., CTG, NSPS, NESHAP) that help 

define RACT. (RACT-SIP section 5). 

EPA Response. We agree that there are currently no federal rules or guidance to help define 

RACT specifically for CAFs. As a result, SJVAPCD has some latitude in identifying RACT 

for the local industry. Nonetheless, EPA must ensure that SJVAPCD’s analysis reasonably 

conforms to the CAA RACT requirement. 

As mentioned in C.3.a above, EPA expects to publish CAF emission estimating 

methodologies by November 2011. After that, we plan to determine whether national 

standards for CAFs should be developed. 

 

1

 Telephone conversation between George Heinen (SJVAPCD) and Andy Steckel (EPA) on or 

about May 5, 2009. 
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d. No rule has been approved into the California SIP for this source category that help define 

RACT. (RACT-SIP section 5). 

EPA Response. We believe Rule 4570 was the first regulation in the country specifically 

designed to control VOCs from CAF operations.

2

 Subsequently, other areas in California 

have adopted similar rules, but EPA has not approved those into the SIP. As with C.3.c 

above, this provides latitude for SJVAPCD in defining RACT, but EPA must still ensure 

that the RACT analysis conforms to the CAA. 

e. Rule 4570 is similar or more stringent than analogous rules elsewhere in California. 

(RACT-SIP sections 4.2.2. and 5). 

EPA Response. We believe this is generally correct and important in the RACT 

demonstration. The RACT-SIP identifies a few provisions in other areas that appear more 

stringent, and SJVAPCD is considering these provisions as possible revisions to Rule 4570. 

f. Rule 4570 implements Best Available Retrofit Control Technology (BARCT) for large CAFs, 

and BARCT is more stringent than RACT. (RACT-SIP section 5). 

EPA Response. The State’s BARCT requirement can help demonstrate that federal RACT 

is generally implemented in California. Again, however, EPA should independently review 

whether local implementation of BARCT and RACT conforms to the CAA RACT 

requirement. 

g. Rule 4570 measures have been required as BACT in individual permits issued by SJVAPCD 

and approved by EPA. (RACT-SIP sections 4.2.1 and 5). 

EPA Response. Since current BACT should be at least as stringent as RACT, this helps 

support the argument that Rule 4570 implements RACT. However, it is not sufficient in 

itself to demonstrate RACT generically because: 

a. BACT determinations consider site-specific factors which may indicate that specific 

controls are feasible in one situation, but not in another. Therefore, controls that are 

BACT for one source may not be BACT or even RACT for others. 

b. Even when site-specific factors are not important, menu-based rules theoretically might 

allow some sources to implement BACT while others avoid even RACT. For example, 

theoretically, a specific permit could implement BACT because a source selected menu 

options X, Y & Z which greatly reduce emissions, but the rule might also allow other 

sources to select options U, V & W which might not fulfill even RACT. 

c. EPA’s lack of comment regarding BACT in individual permits should not be construed 

as EPA concurrence that the rule or the permits implement BACT. We may, for 

 

2 Others have been developed for emissions of dust (e.g., Imperial County Air Pollution Control 

District Rule 217) and ammonia (e.g., Idaho Department of Environmental Quality, Permit by 

Rule, Docket 58-0101-0502). 
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example, simply have chosen not to review the permits because of competing resource 

demands. 

h. Extensive variability among CAFs requires a menu-based regulation instead of establishing 

specific requirements for classes of similar facilities. (RACT-SIP sections 1.2.1, 2.1.2.2.2, 

2.1.2.2.3 and 2.3.1). 

EPA Response. RACT is usually determined by evaluating possible controls and requiring 

specific technologies (e.g., a baghouse) or emission limits (e.g., 10 ppm NOx) that minimize 

emissions with technically and economically available controls. In contrast, Rule 4570 

allows sources to select controls of varying cost and effectiveness from a series of menus. 

We believe this is the first menu-based rule submitted to EPA to implement RACT for 

VOC. Menu-based rules can be appropriate for activities where significant flexibility is 

needed. For example, EPA approved SJVAPCD Rule 4550, which includes menus to 

control dust from on-field agricultural activities, after determining that extensive variability 

in crops, weather, soil type and other farm conditions precluded establishing a specific set of 

generally applicable control requirements. 

The RACT-SIP mentions variability among CAF operations, but provides few examples or 

other details. This is particularly problematic for large CAF operations where animals are 

generally housed in a building (e.g., poultry and swine operations) which is less subject to 

some of the variability that might affect outdoor cattle operations, such as climatic 

conditions, soil type and subsurface geologic structure (RACT-SIP 2.1.2.2.3). 

For example, table 6B of Rule 4570 requires large poultry operations to choose four of 

seventeen possible measures. Four options involve maintenance every 14 days - remove 

caked waste, clean under cages, adjust drinkers and repair pipe leaks. It is not obvious that 

industry variability precludes SJVAPCD from evaluating the cost-effectiveness of these 

controls for the major types of poultry operations. If SJVAPCD determines that they are 

cost-effective for all major source broiler facilities, for example, then it may be appropriate 

to generally require them. Conversely, if SJVAPCD determines that these measures are 

significantly less effective than other generally available measures, it may also be 

appropriate to exclude them from the menus. 

Lastly, in general, the more sources that are subject to a rule, the more likely it is that 

variability among operations might complicate establishment of generally applicable control 

requirements. It seems more likely, therefore, that variability is a concern for dairies, with 

550 sources subject to Rule 4570, than for chicken operations, with only 32 affected sources. 

Since only one swine facility is subject to the rule, variability between operations should not 

be a concern. (RACT-SIP 4.1.3). 

i. Farmers need “flexibility to decide the kind of mitigation measures that will work best for 

their specific operation by taking into consideration animal health and welfare, 

productivity, food safety and overall bio-security issues.” A menu-based rule provides such 

flexibility. (RACT-SIP Section 2.1.2.2.2). 
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EPA Response. Animal health and welfare, productivity, food safety and bio-security are all 

important concerns when developing requirements for CAFs. However, the RACT-SIP 

provides few examples or other supporting detail for how these concerns justify the specific 

menu options provided in Rule 4570. Also, Section 5.4 of the rules seems broad enough to 

address adequately these concerns regardless of the specific menu contents. Lastly, we note 

that the examples that are mentioned in the RACT-SIP focus on cattle operations. 

j. Rule 4570 significantly reduces emissions even if the least costly measures are selected by 

sources. (RACT-SIP sections 4.2.3, 4.4 and 5). 

EPA Response. The RACT-SIP projects 72% emission reductions for swine operations 

regulated by Rule 4570, 36-42% for cattle, and 0% for poultry (section 4.4). We expect 

these estimates will be refined as more information becomes available from NAEMS and 

other research regarding CAF emissions and the effectiveness of various mitigation 

measures in the Rule 4570 menus. While EPA has not defined a presumptive emission 

reduction efficiency for RACT across industries, the emission reductions projected above for 

CAFs are not so unusually large to prove RACT implementation by themselves, particularly 

since RACT for other industries often reduces emissions by 85% or more. 

k. Rule 4570 emission reductions meet assumptions of the overall SIP. (RACT-SIP sections 

4.2.3 and 4.4). 

EPA Response. RACT and attainment are two independent CAA requirements, and 

conformance with an attainment demonstration has no relation to whether a rule implements 

RACT. 

l. Additional mitigation measures are beyond RACT. (RACT-SIP section 4.2.4). 

EPA Response. The RACT-SIP explains why several class two mitigation measures are 

beyond RACT, and thus not required by Rule 4570. These examples focus on various cattle 

operations. Even where we might accept that variability justifies a menu-based approach 

(see C.3.h above) and that class two measures are beyond RACT, the class one options 

could still be evaluated for sufficiency for RACT. 

C.3.h above provides an example where no cost-effectiveness or similar analysis of class 

one poultry menus was provided to justify the specific menus in Rule 4570. Another 

example is that table 6B in the rule directs large chicken houses to choose four of seventeen 

possible measures, but three choices all relate to reducing drips and leaks from drinkers: (a) 

adjusting the height, volume and location of drinkers at least once every 14 days; (b) 

inspecting water pipes and drinkers and repairing leaks at least once every 14 days; and (c) 

using drinkers that do not drip. No analysis is provided to explain, for example: (a) why 

these options are not repetitive and would each further reduce emissions even if all were 

selected; (b) if these measures are effective relative to the other eleven options; (c) if not, 

why are they provided as options; and (d) if so, why they are not universally required and 
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whether it is cost-effective to even increase the frequency from every 14 days. 

Other examples from the swine menus (Rule 4570, table 5) where cost-effectiveness or 

similar analysis may suggest rule revisions include: 

1. It is unclear whether feed specifications described in options A.1-7 are already standard 

industry practice and, therefore, whether selecting these options would result in VOC 

emission reductions compared to other reasonably available controls. 

2. Since we believe feeders are generally located away from side walls in this industry, it 

is unclear how emissions would be reduced compared to other reasonably available 

controls by selecting option A.9, and removing uneaten wet feed within 24 hours of a 

rain event. 

3. Since we believe it is standard industry practice to store grain in weatherproof 

structures, it is unclear how emissions would be reduced, compared to other reasonably 

available controls, by selecting option A.11. 

4. Since we believe standard industry practice includes slatted floors that do not allow 

accumulation of manure, it is unclear how emissions would be reduced, compared to 

other reasonably available controls, by selecting option B.2, and limiting waste in the 

swine pen to 18 inches deep. 

m. Unlike traditional stationary sources where emissions are controlled at the stack, CAFs 

emit over large areas. Even if these fugitive emissions could be captured, they are so dilute 

that traditional point source controls are prohibitively expensive. (RACT-SIP section 

2.1.2.2.1). 

EPA Response. We agree that many emissions from cattle operations (e.g., enteric 

emissions from cattle ranging outdoors) are fugitive and difficult to capture. However, 

RACT-SIP section 4.1.2 states that the, “majority of poultry operations consist of ventilated 

houses. Since these houses have the potential of being fully enclosed and reasonably vented 

to a stack, the emissions from these sources will be considered non-fugitive.” RACT-SIP 

section 1.1.3.5 states that swine are housed similarly in confined buildings. No information 

was provided to demonstrate why add-on control (e.g., a biofilter) is not reasonably 

available to capture and control emissions from large poultry and swine operations. 

n. SJVAPCD estimates that compliance with Rule 4570 costs 9.6% of the net annual profits for 

large dairies and 13% for large beef feedlots. Since agriculture has little ability to pass on 

costs to consumers, more stringent requirements with higher costs are not reasonably 

available. (RACT-SIP Section 2.3). 

EPA Response. SJVAPCD projects no costs of complying with Rule 4570 for poultry 

operations and less than 1% of net profits ($540 total annual cost) for swine. 

D. EPA Evaluation – EPA staff assessment of the rule according to the criteria is summarized 

below. 
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1. Enforceability - In general, Rule 4570 requirements are sufficiently clear, and contain 

adequate monitoring, recordkeeping and other provisions to determine compliance with the rule. 

2. Anti-Backsliding - Since there is no other version of these requirements in the SIP, Rule 

4570 would improve the SIP consistent with CAA §110(l).

3. RACT – Because of the limited history of studying and regulating VOC emissions from 

CAFs (see, e.g., C.3.a, c, and d above), RACT is not clearly defined for these operations. As a 

result, SJVAPCD has some latitude in identifying RACT for the local industry, and we greatly 

respect SJVACPD’s efforts in developing Rule 4570 as the first regulation to control VOC 

emissions from large dairy, feedlot, poultry and other CAF operations. 

While Rule 4570 reduces VOC emissions, we believe there are deficiencies in the demonstration 

that the rule implements RACT. In general, we are concerned that SJVAPCD has not adequately 

demonstrated sufficient variability among CAF operations and has not provided costeffectiveness or other analyses to justify the specific menu options (see C.3.h and l above). 

In light of the NAEMS study and related research activity, however, we believe it is appropriate 

to defer a decision on whether Rule 4570 implements RACT for most affected CAF operations 

for a short period. EPA intends to use the NAEMS results to evaluate both the need and 

mechanism for regulating various CAF activities in the next few years, which should help clarify 

RACT for CAF operations. While major CAF facilities within SJVAPCD are required by the 

CAA to have implemented RACT already, we believe it is good government to postpone a 

decision on whether Rule 4570 fulfils the RACT requirement for dairies and feedlots while 

significant new information and national decisions are expected soon and are likely to affect our 

understanding of RACT. We note that these facilities will still be subject to Rule 4570’s 

significant requirements even while EPA’s decision on RACT is delayed. Nonetheless, we 

recommend below further improvements to the dairy and feedlot requirements in the meantime. 

While much of SJVAPCD’s RACT analysis for dairy and feedlot operations versus poultry and 

swine operations is similar, there are significantly more shortcomings with the demonstration for 

poultry and swine. Taken together, we believe these shortcomings are too great to recommend 

postponing a decision on RACT for poultry and swine operations as we are for dairy and cattle 

feedlot operations. While we are unclear how the NAEMS results will impact our understanding 

of RACT for dairies and feedlots, it is unlikely that they will lead to a finding that SJVAPCD’s 

existing rule and RACT analysis for poultry and swine facilities is sufficient. Factors 

contributing to our different conclusion for poultry and swine operations versus dairy and cattle 

feedlot operations include the following: 

a. Rule 4570 seems to apply to all major cattle sources, but exempts major poultry sources (C.3.b 

above). 

b. There is less evidence of variability in large poultry operations and no evidence of variability 

in swine operations (C.3.h above). 
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c. The animal health, food safety, etc., examples focus on cattle (C.3.i above). 

d. SJVAPCD projects that Rule 4570 will have no emission impacts on poultry operations (C.3.j 

above). 

e. More information is provided to suggest poor cost-effectiveness of class two cattle mitigation 

measures and we have identified, as examples, some specific class one poultry and swine 

measures that warrant additional analysis (C.3.l above). 

f. While much of the emissions from cattle operations may be fugitive, large poultry and swine 

operations appear to include significant enclosed structures that could be treated like 

traditional stationary sources where VOCs are captured and controlled. Nonetheless, 

SJVAPCD has not presented information demonstrating why a bio-filter or other add-on 

control is not cost-effective for large poultry or swine operations (C.3.m above). 

g. Projected costs of complying with Rule 4570 are much higher for cattle (9.6%-13.5% of net 

profits) than for swine (<1%) or poultry (0%) (C.3.n above). 

E. Rule Deficiencies - The SIP submittal fails to demonstrate that this rule adequately 

implements RACT for major poultry and swine operations as required by CAA §182. Of particular 

concern are two deficiencies described below. 

1. The rule exempts poultry operations between 400,000 – 650,000 chickens (Section 4.1); these 

operations should be subject to the rule as major sources of VOC emissions. 

2. The District has not provided adequate analysis supporting the menus applicable to poultry 

and swine facilities. Such analysis should review the availability and effectiveness of controls, and 

may necessitate rule revisions to ensure that the rule does not allow implementation of relatively 

ineffective control measures when more effective measures are reasonably available to a class of 

operations. Sections C.3.h, l and m above identify a few examples of they type of concerns with 

the menus that should be addressed by this analysis. 

F. 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 rule is amended. 

1. We support current SJVAPCD efforts to analyze whether other areas (e.g., SCAQMD) have 

adopted provisions that could improve Rule 4570. 

2. While we are deferring a decision on whether Rule 4570 implements RACT for dairy and 

other cattle operations at this time, we recommend that SJVAPCD nonetheless perform the 

analysis described in section E.2 for the menus for dairy and cattle operations in addition to the 

menus for poultry and swine, and revise the rule as appropriate to ensure that the rule does not 

allow implementation of relatively ineffective control measures when more effective measures are 
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reasonably available to a class of operations. 

3. It is unclear why Section 5.3 requires compliance with the permit application rather than the 

permit as issued, and why an entire year is routinely needed for compliance. We recommend 

revising this section to read, “Owners/operators of any CAF shall implement all VOC emission 

mitigation measures, as contained in the permit application, on and after 365 days from the 

permit issuance date.” 

4. Sections 5.4 and 5.5 could be revised to be more consistent with national policy on excess 

emissions (State Implementation Plans: Policy Regarding Excess Emissions During Malfunctions, 

Start-up, and Shutdown, EPA, September 20, 1999). This policy requires that the frequency and 

duration of excess emissions caused by setting aside mitigation measures due to unusual conditions 

be minimized while the unusual conditions are addressed. If SJVAPCD anticipates that certain 

mitigation measures may cause problems based on experience with the rule, those mitigation 

measures could be specified in this section to narrow its application. 

5. Sections 5.6 - 5.10 could be revised as follows to improve rule compliance and effectiveness: 

a. Where mitigation measures specify time to implement a measure (30 days, 48 hours, etc.) and 

timeliness is related to reducing VOC emissions, insert the language “as soon as possible, but 

no later than...” 

b. Water trough leaks could be repaired “as soon as possible, but not later than” a specified 

period. 

6. Sections 5.11 and 5.13 allow sources to trade mitigation measures from the menus or submit 

entirely different emission reduction plans outside of the menu options. We recommend 

SJVAPCD develop standardized protocols and emission estimating tools to help facilities meet 

the equivalency or percent reduction requirements of these provisions. 

7. Section 5.13 sets a 30% emission reduction target for facilities developing an original 

emission mitigation plan. We recommend revising this target consistent with the minimum 

emission reductions that are projected for facilities that use the menu-based emission mitigation 

plan, 36-72% (See page B-3, Table 3, in “Appendix B: Emission Reduction Analysis for 

Proposed Rule 4570”, dated June 15, 2006). Alternatively, this provision could be deleted if a 

permit review shows that the provision has not been used. 

8. Section 7.1.1.2 should require appropriate records of animal waste removal (e.g., disposal 

dates, methods, locations, quantities) consistent with the applicable mitigation measure to 

demonstrate compliance with the measure and the emission reduction plan. 

9. Section 7.2 should specify compliance testing sufficient to ensure continuous compliance 

with each mitigation measure. We also recommend specifying requirements to properly operate 

and maintain biofilters, scrubbers, digesters, aeration units and other control devices. See, for 

instance, SJVAPCD Rule 4565 requirements for operation, inspection and maintenance of 
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biofilter and aerated static piles. Also consider whether more frequent compliance testing of 

lagoons is warranted by variation in seasonal temperature and nutrient loading. 

10. Section 7.3 could be revised to also reference EPA test methods for VOC capture and control. 

G. EPA Action - The submitted Rule 4570 clearly strengthens the SIP, and the associated 

District staff report projects the rule will reduce VOC emissions an estimated 17.7 to 21.0 tons per 

day. The rule largely fulfills the relevant CAA section 110 and part D requirements, but the 

deficiencies discussed in section E above preclude full SIP approval. EPA staff recommend a 

simultaneous limited approval and limited disapproval of Rule 4570 pursuant to CAA sections 

110(k)(3) and 301(a), and a deferral on finding whether the rule implements RACT for dairy and 

cattle operations. Since the deferral and deficiencies regard only RACT, they do not undermine the 

District’s projected emission reductions for this rule. If the NAEMS and other studies significantly 

revise our understanding of CAF emissions in the future, the District may need to revise the 

projected VOC emission estimates for CAF sources and the projected emission reductions 

associated with the rule. 

H. Attachments

1. SJVAPCD Rule 4570, Confined Animal Facilities, adopted June 18, 2009. 

2. “Final Staff Report for Proposed Re-Adoption of Rule 4570 - Confined Animal Facilities,” 

SJVAPCD, June 18, 2009; and, its “Appendix C - 2006 Final Staff Report Submitted With For 

Rule 4570 (Confined Animal Facilities),” June 15, 2006 Final Staff Report without Appendices. 

3. “Reasonably Available Control Technology (RACT) Demonstration for Ozone State 

Implementation Plans (SIP)” SJVAPCD, April 16, 2009 (pages 4-99 to 4-169). 

I. Additional References

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

EPA OAQPS, May 25, 1988. 

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

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

3. Portions of the proposed post-1987 ozone and carbon monoxide policy that concern RACT, 

52 FR 45044, November 24, 1987. 

4. “State Implementation Plans, General Preamble for the Implementation of Title I of the 

Clean Air Amendments of 1990” 57 FR 13498, April 16, 1992. 
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5. “Preamble, Final Rule to Implement the 8-hour Ozone National Ambient Air Quality 

Standard” 70 FR 71612; November 29, 2005. 

6. Letter from William T. Hartnett to Regional Air Division Directors, “RACT Qs & As – 

Reasonable Available Control Technology (RACT): Questions and Answers,” EPA, May 18, 

2006.