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Kay, Rynda

From: Jeannine Tackett [Jeannine.Tackett@valleyair.org]

Sent: Friday, December 20, 2013 4:39 PM

To: Kay, Rynda

Cc: Perez, Idalia; Steckel, Andrew; Todd DeYoung; samir.sheikh@valleyair.org; Errol Villegas; 

Jessi Fierro

Subject: RE: Status of changes to the Rule 9610 MOP/Annual Report?

Attachments: Rynda's Email questions 12-2013.docx

Rynda, I have attached our responses to your questions. I will be out of the office next week. Hope you have a 

wonderful holiday. 

Jeannine Tackett 

Senior Air Quality Specialist 

Strategies & Incentives Dept. 

San Joaquin Valley APCD 

559-230-5843 ** fax 559-230-6112 

From: Kay, Rynda [mailto:Kay.Rynda@epa.gov] 

Sent: Monday, December 16, 2013 2:31 PM 

To: Todd DeYoung; Jeannine Tackett 

Cc: Perez, Idalia; Steckel, Andrew 

Subject: Status of changes to the Rule 9610 MOP/Annual Report? 

Hi Todd and Jeannine, 

Idalia sent some question to Anna this morning that are needed to move forward with our action on the contingency 

measure SIP. 

We are simultaneously trying to move forward with our proposal on 9610. Because of this, Idalia and I wanted to checkin to ask about the status of the MOP/Annual Report changes for Rule 9610. Do you have an estimate of when we can 

expect these changes? 

You all had made many of the changes last time we spoke, I believe these were the remaining items you were working 

on: 

NRCS

1. Guidelines listed in the MOP are not complete. The following documents are not listed: 

a. CPS-372 O&M (updated document not listed) 

b. FY 2009-2011 Guidelines (not listed) 

c. CPS-372 Specification (updated not listed) 
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2. Explanation of how ownership is verified 

3. Explanation of how existing equipment usage is verified 

4. 2-for-1 quantification methodology 

Other

5. For Portable Ag, SBx2 3 allows for 10yr project life up to the compliance date – specify that for projects in the 

Annual Report, the project lifetimes do not extend past regulatory deadline 

6. For electric irrigation pump replacements, the emission reductions calculated pre- and post- Stationary and 

Portable ATCM compliance deadline are different. Can you include these values/years in the Demonstration 

Report? 

7. On page 29 of the Demonstration Report, add the outcome for the project that “had completed its 

implementation phase and had a reduction in emissions.” 

8. The “missing table” referred to in the last sentence to the second paragraph of page 30. 

Thanks, 

Rynda 

______________________________________________________ 

Rynda Kay, Air Division, Rules Office 

415.947.4118 kay.rynda@epa.gov

US EPA Region 9, 75 Hawthorne St (AIR-4) San Francisco, CA 94105 
NRCS

1. Guidelines listed in the MOP are not complete. The following documents are not listed:

a. CPS-372 O&M (updated document not listed) Need direct link from NRCS 

b. FY 2009-2011 Guidelines (not listed) Need direct link from NRCS 

c. CPS-372 Specification (updated not listed) Need direct link from NRCS 

2. Explanation of how ownership is verified

Current version of Practice Standard 372 has following statement:

“An existing engine must have been owned by the producer and operated in California for at least 

the past 12 consecutive months prior to commencing conservation plan development or the date of 

a contract application. 

Prior year projects required proof of land ownership and actual farming activities through 

documents with the Farm Service Agency. Each tractor replaced had to be connected to a specific 

piece of land that was currently being farmed. 

3. Explanation of how existing equipment usage is verified 

Consistent with the Moyer agricultural off-road replacement guidelines, baseline usage is provided 

by the grantee through the NRCS application process, and then tracked through ongoing reporting. 

While not necessary under the Moyer guidelines, during the application process, NRCS staff assesses 

the reported baseline usage based on their expertise regarding farming practices, size of farm, etc. 

(such as row crops, seasonal crops, orchards, or dairy). 

4. 2-for-1 quantification methodology (Continuing to work with NRCS)

Other

5. For Portable Ag, SBx2 3 allows for 10yr project life up to the compliance date – specify that for 

projects in the Annual Report, the project lifetimes do not extend past regulatory deadline. All 

ag projects using the 10-year project life were fully surplus to regulation during the entire 

reported project life.

6. For electric irrigation pump replacements, the emission reductions calculated pre- and postStationary and Portable ATCM compliance deadline are different. Can you include these 

values/years in the Demonstration Report? All electric irrigation pump replacement projects 

included in the 2013 Annual Demonstration Report were fully surplus to Rule 4702/ATCM 

requirements during the entire reported project life. 
7. On page 29 of the Demonstration Report, add the outcome for the project that “had completed 

its implementation phase and had a reduction in emissions.” Updates have been made to the 

2013 Annual Demonstration Report include the outcome of the above mentioned project.

8. The “missing table” referred to in the last sentence to the second paragraph of page 30. No 

projects to report. 2013 Annual Demonstration Report will be updated to more clearly state.