Air Resources Board 

Mary D. Nichols, Chairman 

Linda S. Adams 1001 1 Street P.O. Box 281 5 Arnold Schwarzenegger 

Secretary for Sacramento, California 95812 - www.arb.ca.gov Governor 

Environmental Protection 

May 20, 2010 

Mr. Jared Blumenfeld, Administrator 

U.S. Environmental Protection Agency 

Region 9 

75 Hawthorne Street 

San Francisco, California 941 05 

Dear Mr. Blumenfeld: 

This is to request delegation of authority by the Air Resources Board on behalf of the 

Santa Barbara County Air Pollution Control District (District) for the implementation and 

enforcement of federal Clean Air Act Section 11 2 maximum achievable control 

technology (MACT) standards for area sources not covered by the 40 Code of Federal 

Regulations Part 70 program. 

The Air Division of your office indicated, in an October 22, 2002 letter to the air quality 

management and air pollution control districts, that they have demonstrated adequate 

authorities and resources to receive delegation for area sources, and encouraged the 

districts to seek delegation for the unchanged MACT standards implementation. 

We have received a letter of intent (copy enclosed) from the District requesting 

delegation to implement the unchanged MACT standards for area sources. We 

understand that this is a one time request and upon the approval of the request, the 

District will have the authority to implement and enforce existing area source standards 

unchanged as promulgated by the U.S. Environmental Protection Agency (U.S. EPA). 

Additionally, if the request is granted, the District will receive delegation of any future 

area source standards or revisions without any additional action from the District or 

U.S. EPA. We are hereby requesting delegation on behalf of the District for the 

implementation and enforcement of the unchanged MACT standards, with the exception 

of the perchloroethylene dry cleaning standard and the chromium electroplating 

standard for which statewide or district rules have already been approved and 

delegated by the U.S. EPA. 

The energy challenge facing California is real. Every Californian needs to take immediate action to reduce energy consumption 

For a 6st of simple ways you can reduce demand and cut your energy costs, see our website: http:llwww.arb.ca.qov. 

California Environmental Protection Agency 

Printed on Recycled Paper 
Mr. Jared Blumenfeld, Administrator 

May 20, 2010 

Page 2 

Thank you for processing this request. If you have any questions, please call 

Mr. Jorge L. Fernandez, Chief, Program Evaluation Branch, Stationary Source Division, 

at (91 6) 445-7800. 

Sincerely, 

~obert D. Fletcher 

Deputy Executive Officer 

Enclosure 

cc: Mr. Terence E. Dressler 

Air Pollution Control Officer 

Santa Barbara County Air Pollution Control District 

260 North San Antonio Road, Suite A 

Santa Barbara, California 931 10-1 31 5 

Ms. Mae Wang 

U.S. Environmental Protection Agency 

Region 9 

75 Hawthorne Street 

San Francisco, Califorr~ia 941 05 

Mr. Jorge L. Fernandez, Chief 

Program Evaluation Branch 

Stationary Source Division 

Air Resources Board 
Our Vfrlon % Clean Air 

anta Sarbara County 

Air Pollution Control District 

VIA EMAIL TO PATRICK AU 

April I, 2010 

Michael J. Guzzetta, Manager 

Rule Evaluation Section 

Program Evaluation Branch 

Stationary Source Division 

California Air Resources Board 

P.O. Box 28 1 5 

Sacramento, CA 958 12 

SURJEC'I': Request for EPA to Delegate Authority for Implementing and Enforcing Area Source 

MACT Sta~ida~ds to the Santii Barbdra County Air Pollutioi~ Control District 

Dear Mr. Guzzetta: 

It is our understanding that the Santa Barbara County Air Pollutiorl Control District has already received 

delegation for unchanged federal emissions standards promulgated under section 1 12, Hazardous Air 

Pollutants, of the federal Clean Air Act (CAA) Car sources covered by the 40 CFK Part 70 program. We 

would like to complete the delegation to our District for implementing and enforcing these standards by 

requesting delegation of the unchanged section 112 standards as they apply to sources that are not subject 

to Part 70 permit requirements. Please submit a request to EPA for this delegation on behalf of thc Santa 

Barbara County Air Pollution Corltrol District. 

We believe that the District has adequate legal authorities, resources, and abilities to ilnplenient and 

enforce these standards. We also believe that those criteria have been sufficiently demonstrated through 

CAKB's July 6, 1995, dry cleaning delegation and equivalency request for approval of its demonstration 

that California has adequate authorities and resources to iinplement and enforce CAA section 1 12 

prograins and rules. We understand that if our request for delegation is granted, then the District will 

receive delegation of each future CAA section 1 12 area source standard 90 days after pro~nulgation of 

that standard, without any additional action from the 1)istrict or EPA. CARB will notify the District of 

iiew standards soon after they are promulgated. If we do not wish to receive delegation for a particular 

standard, then we will notify the EPA Region 9 office in writing to decline delegation of the specitic . 

standard. The District will receive delegation of any existing CAA section 1 12 area source standards 

upon the approval of our request, with the excep~ion of the perchloroethylene dry cleaning standard and 

the chromium electl-oplating standard for which statewide or district rules have already been approved and 

delegated. 

If you have any questions regarding this matter, please contact Douglas Grapple at (805) 961-8883. 

Technology and t:~~vironrnental ksscssment 

cc: Mae Wang, EPA Kegion 9 (via cmail) 

!e!ence F [)ress~e; Air Poiiitt~~il Cootro! Officer 

260 North Son Antor:;o Rood, Su~lc? A - Snnta Borha!~, CA 931 !!I , www.sbcopcd org . 805.961 .RBOCi , 805.961.8H01 (iclx!