# 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 Nitrogenfrom Commercial Food Ovens (Adopted November 7, 

### 2014); Rule 219: Equipment Not Requiring a Written Permit Pursuant to Regulation II (AmendedMay 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 emis s ions limits
. Rule development has addressed the feasibility issues by delaying compliance dates, specifying equipment rule exemptions and relax in g 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 emis s ion 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 pollutantNOx Rule Development Page 2 carrying capac1t1es
. (See the AQMP Final Controlled Emissions Projection Algorithm (CEPA) Source Emi ss ion Reduction s Summaries provided in Appendix V Modeling Attainment Demonstration s: Attachments 7 for th e 2007 plan and Attachments 2 and 3 for the 2012 plan)
. With submission of the ce11ified 2013 ambient PM 2.5 data to EPA AQS, the Basin demonstrate s compliance with the 1997 annual average PM 2.5 standard. On December 9, 2014, U.S. EPA published in th e Federal Register its proposal to determine that the Basin had attained the 1997 annual and 24-hour PM 2. 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 attai nment 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 PM 2.5 standard with a 2013 design value of 36.6 ~tg/m 3 or 4% greater than the standard. As shown in Table I , implementation of Rules 219/222, 1110.2 , 1111 , 1147 and 1153
. I will result in 0.21 TPD of NOx emi ss ion reducti ons foregone in 20 15
. The amendments to Rule 1147 will de lay compiiance in 2015 and 2016, but will increast comp:iancc in 2017 and 2018 to cffset the net imp act of the de lay. (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 1147 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 reduction s foregone due to the exemption of two remotely located I C engines. Amendments of Rules 219/222 and adoption of Rule 1153.1 both extracted se lected categories of equipment from Rule 11 4 7 jurisdiction and account for 0.04 and 0.06 TPD NOx emissions reduction s 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 PM 2 .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 PM 2

### .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 re spective ly . De lays in NOx emissions reductions due to implementation of alternate compliance plans or modifications to compliance schedules beyond 2020 do not impact the attainment demonstration s. 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 Rul es 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 Rule s 219/222, 1111, 1110.2 , 1147 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 emi ssion reduction s. 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 I0/20 IO-jul9- 03 8
.pdf?sfvrsn=2 Rule I I47: 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 , 1147 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 1147 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 sale s of electric leaf blowers through the SCAQMD Leaf Blower Exchange Program.