### OCTOBER 22, 2013 RESPONSE TO COMMENTS AIR POLLUTION CONTROL DISTRICT BOARD HEARING

COMMENT FROM COMMENT RESPONSE Comment 1 (Letter) Imperial County Air Pollution Control District Division of Engineering and Permitting The Division of Engineering and Permitting for the Imperial County Air Pollution Control District reviewed the newly proposed rules 400.3 and 400.4 Comment 1 A proposed change to section A.1 of Rule 400.3 was recommened for consistency to the California Air Resource Board's applicablility of Stationary and Portable Air Toxic Control Measures and Rule 202, Exemptions. The change would make the applicability of Rule 400.3 to IC Engines greater than 50 hp After review we agree with the justification provided by the Engineering and Permitting section. The change to the rule was as follows: the words "of 50 or" were deleted and after the word "greater" but before the word "that" the words "than 50" were inserted.

Comment 2A proposed change to section D.4 for Rule 400.3 was made to included sections F and G of the rule to the existing exemption for those engines that operate 100 hours or less The intent of the exemption is to only exempt "emergency" generator from compliance with threshold found in Rule 400.3; however the requirements in the Authority to Construct permit should be enforced through the requirements in sections F and G of the rule.
Comment 3The commenter noted that Rule 400.4 had the incorrect reference to 400.3 in the numbering of the pages The change was made to reflect 400.4

Comment 2 (E-mail) 

### Rick Wolery El Toro Land & Cattle Mr. Rick Wolery asked 5 questions. Of the 5 questions only the 1st question is directly associated with the proposed rules Comment 1 Does Rule 400.3 apply to all Ag Engines, No Ag Engines or only Certain Engines? Rule 400.3 as written applies to all Internal Combustion Engines (IC Engine) with a brake horsepower greater than 50 that is required to obtain a District permit. If an agricultural operation has an IC Engine greater than 50 horsepower and is not exempt per Rule 202 then the Rule applies. This rule is applicable to those agricultural engines operated at major agricultural sources.

### OCTOBER 22, 2013 RESPONSE TO COMMENTS AIR POLLUTION CONTROL DISTRICT BOARD HEARING

COMMENT FROM COMMENT RESPONSE Comment 2 (E-mail) 

### Rick Wolery El Toro Land & Cattle Mr. Rick Wolery asked 5 questions. Of the 5 questions only the 1st question is directly associated with the proposed rules Comment 2 Is Ag required to register all engines larger than 49 HP with the district even if they are Ag exempt? All engines greater than 50 horespower must either obtain a certification through the State of California as a portable engine, register with the Air District or obtain an operating permit. We strongly suggest you contact the Air District Engineering to discuss which of these fits your operation.
Comment 3Are Tier 0 engines illegal for Ag use? All tier 0 engines regardless of intent or use are prohibited. Comment 4At what stage do the different Tier's phase out for replacement? The phasing out of engines depends on the use of the engine. However, generally speaking currently all greater than 50 horsepower must be tier at a minimum tier 2 however without specific information such as the use of the engine, year of operation and a host of other conditions a general answer cannot be given. We strongly recommend that you consult with the Engineering department for specific information.

Comment 5 Is ther any financial help for replacements? As the stringency of the regulations come into a sunset date the available funding sources become less applicable because all incentive monies are based on surplus and cost-effectiveness. Comment 3 (E-mail) 

### United States Environmental Protection Agency - Laura Yannayon Comment 1 Commenter references administrative changes in Rule 207 All administrative changes were made

Comment 2 Commenter references administrative changes in Rule 206 The word "containments" was changed to "Contaminants" Comment 3 Commenter references administrative changes in Rule 101 All administrative changes were made

### OCTOBER 22, 2013 RESPONSE TO COMMENTS AIR POLLUTION CONTROL DISTRICT BOARD HEARING

COMMENT FROM COMMENT RESPONSE Comment 4 (E-mail) 

### United States Environmental Protection Agency - Andrew Steckel Comment 1 Commenter simply wanted to reaffirm and to make sure that the definition of a "military base" is for closure The intent of the definition is to identify those military bases that are closing.

Comment 5 (Letter)

### American Coatings Association Letter of Support

Commenter is supporting the revisions to Rule 101 specifically the changes which exempt Tertiary-Butyl Acetat (TBAC), Dimethyl Carbonate and Propylene Carbonate Comment noted

Comment 6 (Letter) 

### Lyondel Base Letter of Support Commenter is supporting the revisions to Rule 101 specifically the changes which exempt Tertiary-Butyl Acetat (TBAC) and Propylene Carbonate Comment noted