South Coast 

Air Quality Management District 

21865 Copley Drive, Diamond Bar, CA 91 765-41 78 

(909) 396-2000 • www.aqmd.gov 

Andrew Steckel, Rulemaking Office Chief 

United States Environmental Protection Agency 

Region IX 

75 Hawthorne Street 

San Francisco, CA 94105-3901 

Re: Ongoing NOx rule development emissions re.luci'ions (forgoue) issues: 

May 20, 2015 

Rule 1111: Reductio11s ofNOx Emissio11sfro111 Natural Gas-Fired, Fan-Type Central 

Furnaces (Amended September 5, 2014); 

Rule 1110.2: Emissions from Gaseous and Liquid Fueled Engines (Amended September 7, 

2012); 

Rule 1153.1: Emissions of Oxides of Nitrogen from Commercial Food Ovens (Adopted 

November 7, 2014); 

Rule 219: Equipment Not Requiring a Written Permit Pursuant to Regulation II 

(Amended May 3, 2013); 

Rule 222: Equipment Requirements for Specific Emission Sources Not Requiring a 

Written Permit Pursuant to Regulation II (Amended May 3, 2013); and 

Rule 1147: NOx Reductions from Miscellaneous Sources (Amended September 9, 2011) 

SCAQMD staff is providing a response to your comments based on your review of Rules 219/222, 

1110.2, 1111 , 1147 and 1153.1. Over the past three years, staff has brought rule amendments and new 

rules to the Governing Board to address ongoing implementation issues due to technology forcing 

emissions limits. Rule development has addressed the feasibility issues by delaying compliance dates, 

specifying equipment rule exemptions and relax ing emissions limits. As a consequence, selected SIP 

emission reductions from rule implementation have been forgone or delayed. The range of the emission 

reductions forgone varies each year from 2015 through 2020 dependent upon rule implementation 

schedule and compliance options selected by the affected sources. The annual magnitude of the emission 

reductions forgone is summarized in Table I for each of the six years culminating in a 0.15 TPD total in 

2020 and beyond. 

The 2007 and 2012 Air Quality Management Plans (AQMP) both recognized em1ss1on reductions 

foregone due to inability to attain technology forcing emissions limits contained in adopted rules as a 

potential issue that could jeopardize future NAAQS attainment. To account for potential emission 

reduction shortfalls due to technology assessments, the EPA-approved 2007 SIP has a set aside of 2.0 

TPD NOx in the controlled inventories for both 2014 and 2023 (page III-2-34 in Appendix III) and the 

2012 AQMP has a set-aside of 1 TPD NOx emission reductions for 2014 and 2 TPD for 2023 in the 

controlled inventories (page III-2-59 in Appendix III). The set aside emissions are included in the 

controlled remaining emission inventories used in the attainment demonstration to determine pollutant 
NOx Rule Development 

Page 2 

carrying capac1t1es. (See the AQMP Final Controlled Emissions Projection Algorithm (CEPA) Source 

Emission Reductions Summaries provided in Appendix V Modeling Attainment Demonstrations: 

Attachments 7 for the 2007 plan and Attachments 2 and 3 for the 2012 plan). 

With submission of the ce11ified 2013 ambient PM2.5 data to EPA AQS, the Basin demonstrates 

compliance with the 1997 annual average PM2.5 standard. On December 9, 2014, U.S. EPA published in 

the Federal Register its proposal to determine that the Basin had attained the 1997 annual and 24-hour 

PM2.5 standards. Ln its January 2015 Draft Supplement to the 24-Hour PM2.5 State Implementation Plan 

for the South Coast Air Basin, the SCAQMD updated its attainment demonstration for the 2006 NAAQS 

to reflect a 2015 attainment date with respect to the recent requirements under Subpait 4, of the CAA. 

Currently only one site in the Basin, Mira Loma, exceeds the 24-hour PM2.5 standard with a 2013 design 

value of 36.6 ~tg/m3 

or 4% greater than the standard. 

As shown in Table I, implementation of Rules 219/222, 1110.2, 1111 , 114 7 and 1153 . I will result in 0.21 

TPD of NOx emission reductions foregone in 20 15. The amendments to Rule 1147 will delay 

compiiance in 2015 and 2016, but will increast comp:iancc in 2017 and 2018 to cffset the net impact of 

the delay. (Emissions reductions from Rule 1147 will increase to 0.12 TPD NOx in each of2017 and 

20 18). In addition, the projected emissions foregone from Rule 114 7 compliance delays due to 

implementation of the mitigation fee option are expected to be offset by sales of e lectric leaf blowers 

through SCAQMD's Leaf Blower Exchange Program. Amendments to Rule 1110.2 contribute 0.03 TPD 

emissions reductions foregone due to the exemption of two remotely located IC engines. Amendments of 

Rules 219/222 and adoption of Rule 1153.1 both extracted selected categories of equipment from Rule 

11 4 7 jurisdiction and account for 0.04 and 0.06 TPD NOx emissions reductions foregone, respectively. 

Amended Rule 1111 delayed the initial 2014 compliance implementation date to April 2015 thus 

contributing 0.02 TPD foregone emissions reductions for each following year. Like the alternate 

compliance plan option described for Rule 1147, Rule 1111 compliance delays for the implementation of 

the mitigation fee option are expected to be offset by sales of electric leaf blowers through the SCAQMD 

Leaf Blower Exchange Program. 

The foregone emission reductions do not impact the modeled 2015 attainment demonstration for the 2006 

24-hour PM2.

5 standard because they were accounted for through the 1 TPD NOx set aside in the 2014 

controlled inventory. Note: the 2015 24-hour PM2.5 attainment demonstration has been interpolated 

from the 2014 and 2019 modeling simulations. Both simulations had the 1 TPD NOx set aside included 

in the modeling attainment inventory. Daily forecasted restrictions on agricultural and residential wood 

burning are projected to bring the Basin into compliance with the 2006 PM2.s standard by December 3 l, 

20 15. 

The attainment demonstrations for the revoked I-hour and 1997 8-hour ozone standards are targeted for 

2023 and 2024 respectively. Delays in NOx emissions reductions due to implementation of alternate 

compliance plans or modifications to compliance schedules beyond 2020 do not impact the attainment 

demonstrations. The l TPD and 2 TPD NOx set-aside emissions in the 2014 and 2023 controlled 

inventories are sufficient to account for the nominal loss of emissions (0.13 TPD) due to the amendments 

of Rules 219/222 and Rule 1110.2 and adoption of Rule 1153 .1 which extracted selected categories of 

equipment from Rule 1147 jurisdiction. 

The staff repo1ts for Rules 219/222, 1111, 1110.2, 114 7 and 1153 .1 summarize the changes to rule 

language that result in the foregone emission reductions. Responses to comments for Rules 1111 and 

I 153 . I provided in the staff repo11s specifically cite the use of the set aside emissions to replace foregone 

emission reductions. The four key staffrepo11s are posted on the SCAQMD website at: 
NOx Rule Development 

Page 3 

Rules 219/222: http://www.aqmd.gov/docs/default-source/ Agendas/Governing-Board/2013/2013-

may3-028.pdf?sfvrsn=O 

Rule 1111: http://www.aqmd.gov/docs/default-source/ Agendas/Governing-Board/2014/2014-sep5-

03 2. pdf?sfvrsn=2 

Rule 1110.2: http://www.aqmd.gov/docs/default-source/ Agendas/Governing-Board/20 I 0/20 I O-jul9-

03 8.pdf?sfvrsn=2 

Rule I I 4 7: http://www.aqmd.gov/docs/default-source/ Agendas/Governing-Board/2011/201 l-sep9-

034.pdf?sfvrsn=2 

Rule 1153. I: http://www.aqmd.gov/docs/default-source/ Agendas/Governing-Board/2014/2014-

nov7-024 .pdf?sfvrsn=O 

Staff believes that the discussion provided above sati:;fies your concerns to the SIP acceptability of the 

amendments to Rules 11 I I, 114 7 and 1110.2 which either exempted equipment or delayed rule 

implementation, and the amendment of Rules 219/222 and adoption of Rule 1153 .1 which resulted in 

emissions foregone from Rule 114 7 thereby meeting the requirements of CAA section 110(1). Staff also 

believes that the emissions reduction forgone from the aforementioned rule actions are covered by the 

2007 and 2012 SIP emissions set asides and will not adversely impact the expeditious attainment of the 

NAAQS. We will continue to track emissions impacts resulting from various technology assessments 

associated with future rule limits to ensure that our SIP commitment is met. If you have any questions or 

need further information please contact Joseph Cassmassi, the Planning and Rules Director responsible 

for the Rule 1111 amendments at (909) 396-3155 or by e-mail at jcassmassi@aqmd.gov. 

Philip Fine, Ph.D. 

Deputy Executive Officer 

Planning, Rule Development, & Area Sources 

Cc: Nicole Law, U.S. EPA Region IX 

Idalia Perez, U.S. EPA Region IX 
Table 1. 

NOx Rule Development 

Page 4 

NOx Emissions Reductions Forgone (TPD) Due to Delays in Compliance Dates, Exemptions 

and Relaxing Emissions Limits 

Rule 2015 2016 2017 2018 2019 2020 

1110.2 0.03 0.03 0.03 0.03 0.03 0.03 

1111 * 0.02 0.02 0.02 0.02 0.02 0.02 

- - ·- - ·- -- ·------ -

1147* 0.06 0.06 -- -- -- --

Froml147 

to: 

222/219 0.04 0.04 0.04 0.04 0.04 0.04 

1153 .1 0.06 0.06 0.06 0.06 0.06 0.06 

Total 0.21 0.21 0.15 0.15 0.15 0.15 

*Emissions foregone from compliance delays due to the Rule 1147 and Rule 1111 mitigation fee 

option were projected to be offset by sales of electric leaf blowers through the SCAQMD Leaf 

Blower Exchange Program.