Final Staff Report with Appendices

 For Revised Proposed Amendments to Rule 4702 

SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

FINAL STAFF REPORT 

Revised Proposed Amendments to 

Rule 4702 (Internal Combustion Engines) 

August 18, 2011 

Prepared by: Anna Myers, Senior Air Quality Specialist, Plan Development 

 Sandra Lowe-Leseth, Air Quality Engineer, Permits 

Reviewed by: Brian Clements, Senior Air Quality Engineer, Permits 

Ramon Norman, Air Quality Engineer, Permits 

Patrick Houlihan, Senior Air Quality Specialist, Compliance 

Kevin McCaffrey, Senior Air Quality Specialist, Incentives 

Mike Oldershaw, Manager, Compliance 

Leonard Scandura, Manager, Permits 

Errol Villegas, Program Manager, Strategies and Incentives 

Samir Sheikh, Director, Strategies and Incentives 

I. SUMMARY 

The San Joaquin Valley Unified Air Pollution Control District (District) is committed to 

protecting public health for all residents in the San Joaquin Valley (Valley) through 

efforts to meet health-based state and federal ambient air quality standards with 

efficient, effective, and entrepreneurial air quality management strategies. One such 

strategy includes a commitment in both the District’s 2007 Ozone Plan (Ozone Plan) 

and 2008 PM2.5 Plan (PM2.5 Plan) to amend Rule 4702 (Internal Combustion Engines) 

to reduce emissions of oxides of nitrogen (NOx) from this source category. 

The proposed amendments to Rule 4702 seek to obtain as much NOx emission 

reductions from the source category as expeditiously practical, technologically feasible, 

and economically reasonable, as determined by the District’s Governing Board. In 

order to provide better service to stakeholders and affected industry, the proposed 

amendments will also simplify and clarify existing rule language and standards. 

Proposed amendments are applicable to non-agriculture operated internal combustion 

engines. Proposed amendments include provisions for limited use engines, point of 

sale requirements for engines rated at 25 to 50 brake horsepower (bhp), more stringent 

NOx emission limits for various types of engines within this category, and SOx 

requirements would be added to rule language. 
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A. Reasons for Rule Development and Implementation 

The federal Environmental Protection Agency (EPA) has classified the San Joaquin 

Valley Air Basin as an extreme non-attainment area for federal ambient air quality 

standard for ozone and non-attainment for the standard for particulate matter with 

aerodynamic diameter of 2.5 micrometers and less (PM2.5). The California Air 

Resources Board (ARB) has classified the basin a severe non-attainment area for the 

state’s ozone standard. As a result of these classifications, the District is required to 

evaluate sources of pollution and create a strategy (plan) for how the District will come 

into attainment of the standards. The ozone and PM2.5 attainment strategies are 

comprised of regulatory and incentive-based measures to reduce emissions of NOx, 

volatile organic compounds (VOCs), sulfur oxides (SOx) as well as directly-emitted 

particulates. 

The Ozone Plan and PM2.5 Plan each identified Rule 4702 (Internal Combustion 

Engines) as part of the District’s attainment strategy. There is no commitment for a 

specific quantity of NOx reductions in either District attainment plan. 

B. Rule Development Process 

Work on this rule-amending project began in 2007 with the adoption of the District’s 

Ozone Plan. District staff began the rule development process with extensive research 

as a part of a feasibility study performed to determine if there was potential from this 

source category for achieving additional emission reductions. 

After the completion of the feasibility study, staff continued to research the District’s 

permits database, industry standards, technological advancements and actions taken 

by other regulatory agencies regarding the technological and economic feasibility of 

amending rule standards to make them more stringent. District staff presented their 

research findings to stakeholders, industry, ARB, and EPA during a public Scoping 

Meeting on June 24, 2010. During the Scoping Meeting staff outlined the potential 

range of the rule project and requested comments, feedback, and cost information from 

all interested parties. It was during the public Scoping Meeting that staff explained to 

stakeholders that research was being conducted as to the feasibility of controlling SOx 

and that staff was considering the replacement of engines with electric motors where 

possible. Staff also explained the decisions as to why certain engine categories would 

not be amended during this rule-amending process; specifying that these decisions 

were based on research, the evaluation of the permits database, and conversations with 

industry. 

District Staff crafted draft rule requirements based on the best available information 

after evaluating the comments received regarding the proposed rule concepts. The 

District then hosted a Public Workshop on September 9, 2010 to present and discuss 

the draft amendments to the rule. The draft amendments to Rule 4702, as presented in 
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September 2010, included requirements that nearly all non-agricultural operated (nonAO) spark ignited engines meet a NOx concentration of 11 parts per million by volume 

on a dry basis (ppmvd) (at 15% oxygen (O2)). Draft VOC and CO limits were also 

considered to be proposed to be lowered. Knowing that the proposed rule requirements 

would potentially be costly to some facilities, the District included an annual fee option 

(similar to Rule 4320), and additional compliance options. 

A socioeconomic focus group was also held during the first public workshop. 

Stakeholders were solicited for more cost information and potential impacts to their 

operations in light of the draft amendments. 

After the September Public Workshop, District staff met several times with stakeholders. 

District staff worked closely with stakeholders to refine the rule requirements and 

address the cost impacts to affected facilities and feasibility concerns of implementing 

various control technologies. Due to the remaining issues, in December 2010, District 

staff provided an update to the District’s Governing Board (Board) on the status of this 

project with plans to bring forth a proposed rule for Board consideration in 2011. 

The District hosted a technical discussion session in January 2011 with the District’s 

Citizens’ Advisory Committee of Industry (CAGI) to solicit further input on issues and 

concerns from affected stakeholders. The comments received from the public, affected 

sources, interested parties, EPA, and ARB during the public workshop, stakeholder 

meetings, and technical session were used to develop the second draft amendments to 

the rule. The new amendments included provisions for engines used on a limited basis, 

meaning they are only used during part of the year. A phased compliance schedule 

was developed to extend compliance deadlines for facilities with multiple engines to 

lessen the financial burden on these facilities. In order to maximize NOx reductions, 

VOC and CO limits were changed back to current levels. Upon further reflection, the 

cyclically loaded and waste gas combustion engines were returned to current NOx 

emission limits. The second draft of the rule was released to the public for comment 

and the District conducted the final public workshop June 22, 2011. 

Staff continued to work diligently with the remaining affected stakeholders and EPA to 

draft the proposed rule. Compared to the June version of the draft rule, the proposed 

rule provides a requirement specific to lean burn engines used for gas compression. 

Additionally, the phased in compliance schedule has been further extended for those 

operators with more than twelve engines at a stationary source. Section IV.B of this 

Final Draft Staff Report provides a detailed discussion for each proposed amendment. 

Pursuant to state law, the District performed a socioeconomic impact analysis. As part 

of the District socioeconomic analysis process, District staff solicited volunteers from 

affected stakeholders and interested parties to participate as members of the 

Socioeconomic Focus Group. District staff convened a meeting of the Focus Group in 

conjunction with the first workshop in September 2010 to assist District staff in gathering 

information on regulatory compliance costs and business impacts resulting from 
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compliance with the draft amendments. The results of the socioeconomic analysis were 

published in a report and presented along with the draft rule amendments to the public 

and interested parties during the June 2011 workshop; at which time staff solicited 

additional feedback from stakeholders. 

The Proposed Rule and Final Draft Staff Report were published and made available to 

affected sources and interested parties prior to a public hearing to consider the adoption 

of the rule by the District Governing Board. The proposed amendments are scheduled 

to be presented to the Governing Board for the public hearing to consider adoption of 

the amendments to the rule on August 18, 2011. 

II. GLOBAL CLIMATE CHANGE AND GREENHOUSE GASES 

The California Global Warming Solutions Act of 2006 (AB 32) created a comprehensive, 

multi-year program to reduce greenhouse gas (GHG) emissions in California, with the 

overall goal of restoring emissions to 1990 levels by the year 2020. In the coming 

years, ARB and the Legislature will be developing policies and programs to implement 

AB 32. The District believes that the evidence and the rationale that climate change is 

occurring is compelling and convincing. In addition to the long-term consequences of 

climate change, the District is concerned with the potential ramifications of more 

moderate but imminent changes in weather patterns. The Valley depends heavily on 

agriculture for its economy and has developed agricultural practices based on the last 

several decades of weather patterns. Unanticipated and large fluctuations in these 

patterns could have a devastating effect on the Valley’s economy. 

While there are many win-win strategies that can reduce both GHG and criteria/toxic 

pollutant emissions, when faced with situations that involve tradeoffs between the two, 

District staff believes that the more immediate public health concerns that may arise 

from an increase in criteria or toxic pollutant emissions should take precedence. The 

San Joaquin Valley Air Pollution Control District’s Governing Board adopted the Climate 

Change Action Plan (CCAP) in August 2008. For California Environmental Quality Act 

(CEQA) requirements, one of the goals of the CCAP is to establish District processes 

for assessing the significance of greenhouse gas impacts. The District has developed a 

policy and guidance for addressing greenhouse gases under CEQA. 
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III. BACKGROUND 

An internal combustion engine is any engine that operates by burning its fuel inside the 

engine. Engines generate power by the combustion of an air/fuel mixture. The main 

types of engines are spark-ignited engines and compression-ignited (or diesel) engines. 

In the case of spark-ignited engines, a spark plug ignites the air/fuel mixture. Sparkignited engines come in several designs such as: two-stroke and four-stroke, rich-burn 

and lean-burn, turbocharged and naturally aspirated. Spark-ignited engines may use 

one or more fuels, such as natural gas, propane, butane, liquefied petroleum gas, oil 

field gas, digester gas, landfill gas, methanol, ethanol, and gasoline. 

Compression-ignited engines rely on heating of the inducted air during the compression 

stroke to ignite the injected diesel fuel. In addition to being classified into compressionignited and spark-ignited, IC engines can be further divided into two-stroke and fourstroke engines. Most diesel engines are four-stroke, while larger diesel engines often 

are two-stroke. Natural gas fired spark-ignited engines are usually four-stroke, but 

some operators prefer two-stroke engines for their applications. 

Most engines are used for activities such as powering pumps, compressors, or electrical 

generators. Engines are used by a variety of private businesses and public agencies 

throughout the Valley. Examples of businesses and industries that use engines that 

could be affected by this project include schools and universities, agriculture, oil and 

gas production and pipelines, petroleum refining, manufacturing facilities, food 

processing, electrical power generation, landfill and waste water treatment facilities, and 

water districts. Many of the permitted compression-ignited engines in the District are 

emergency standby engines that provide backup power when electric service is 

interrupted. 

IV. CURRENT RULE 4702 AND PROPOSED AMENDMENTS 

A. Current Rule 4702 

Rule 4702 (Internal Combustion Engines Phase 2) was adopted in August 2003 and 

was last amended in January 2007. The purpose of Rule 4702 is to limit NOx, CO, and 

VOC emissions from stationary engines. The rule applies to any stationary engines with 

a rated brake horsepower (bhp) greater than 50. The rule requirements are organized 

into two engine categories: those used in agricultural operations (AO) and those used in 

non-agricultural operations (non-AO). The existing NOx concentration limits in Rule 

4702 range from 25 parts per million by volume (ppmv) to 150 ppmv corrected to 15% 

O2, depending on engine category. The VOC and CO concentration limits range from 

250 to 750 ppmv (depending on engine category) and 2,000 ppmv, each corrected to 

15% O2, respectively. 
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B. Proposed Amendments to Rule 4702 

In an effort to simplify rule language and clarify existing requirements, expired language 

was removed, and some rule requirements were reorganized to other sections of the 

rule. The following paragraphs detail the proposed modifications to rule language. See 

Proposed Rule 4702 for exact language. 

1. Rule Title, Section 1.0 Purpose and Section 2.0 Applicability 

The title of the rule would be modified to remove the phrase “Phase 2”. This phrase is a 

holdover from past years and the phrase no longer reflects the rule’s scope. The 

Purpose section of the rule would add SOx to the list of pollutants that are limited by 

rule requirements. In the Applicability section, the minimum brake horsepower (bhp) 

rating of engines subject to the rule would be amended from 50 bhp to 25 bhp. 

2. Section 3.0 Definitions 

The Definitions section would be updated by removing expired language, and some 

existing definitions would be updated for clarity. The definition for low-use engine would 

be re-located from Section 4.0 (Exemptions) to Section 3.0 (Definitions), with no change 

to the meaning of the definition. 

The following definitions would be added to the rule to improve clarity and reflect 

changes to rule requirements: Air Pollution Control Officer (APCO), ARB, California 

reformulated diesel, EPA, higher heating value, limited-use engine, and operator. Also, 

throughout the rule, the word “owner” would be replaced with the word “operator” to 

provide clarity as to who rule requirements are applicable to. It is important to note that 

this change does not change who the rule is applicable to, but is simply a clarification of 

existing rule requirements. 

The June 22, 2011 version of the draft rule and draft staff report contained a draft 

definition of “existing cyclic field gas fueled engines.” This draft definition has been 

removed from the rule because there is no NOx control technology that will allow newer 

cyclically-loaded engines to be controlled below their current emission level, even with 

the latest emission control technology. 

3. Section 4.0 Exemption

Section 4.1 – Exemption From Rule Requirements 

Section 4.1 lists the engines that are exempt from rule requirements. Portable engines 

will be moved from Section 4.3 to Section 4.1.6 and 4.1.7. This change removes 

record-keeping requirements from these engines. 
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Additionally, District staff considered the District’s portable engine program. Engines 

registered in the District’s program keep records as a requirement of District Rule 2280 

(Portable Engine Registration). These records are very similar to the records currently 

required in Rule 4702. The only difference is that Rule 4702 requires records that state 

the hours of operations whereas Rule 2280 records that show how much fuel was 

burned. There is a one-to-one relationship between the amount of fuel burned and the 

number of hours operated, so dropping the Rule 4702 records requirement will not 

reduce the amount of operating information currently available for these engines. 

As originally posted in the July 19, 2011 version of the Final Draft Staff Report for the 

Proposed Amendments to Rule 4702, the language for portable engines could be 

construed that the engine be registered for both the state and District portable engine 

programs. The provision has since been rewritten to clarify that if the engine is 

registered for either program, the engine is exempt from the rule requirements, although 

the District-registered portable engines would still keep records in accordance with Rule 

2280. 

Section 4.2 – Exemption for Emergency Standby Engine or Low Use Engine 

The language in Section 4.2 would be amended to consolidate requirements for 

emergency standby and low-use engines. The language would be streamlined for 

reader clarity. No changes to the current requirements are proposed for this section. 

Section 4.3 Exemption with Recordkeeping Requirements 

Section 4.3.2 would be moved to Section 4.1.6 and 4.1.7 to reflect the removal of the 

record-keeping requirements. This change removes record-keeping requirements from 

these engines. The California Air Resources Board (ARB) recently removed recordkeeping requirements from the statewide portable engine registration program. District 

staff reviewed ARB’s discussion and agreed with ARB’s assessment that the records 

are unnecessary. 

Section 4.4 – Exemption for BACT and Offset Requirements 

Section 4.4 allows an exemption from the requirements of Best Available Control 

Technology (BACT) and Offset requirements of Rule 2201 (New and Modified 

Stationary Source Review Rule) if an existing facility is installing the replacement engine 

for the sole purpose of complying with Rule 4702. Discussions between the District, 

EPA, and ARB continued after the July posting of the Proposed Amendments to Rule 

4702 as to how to clarify this exemption in such a manner that does not violate Federal 

or State laws and mandates. These discussions resulted in the revision of proposed 

amendments. These revisions are not a change in rule requirements, but a clarification 

of the existing exemption. Revised Section 4.4 specifies that for existing facilities, a 

replacement unit installed for the sole purpose of complying with the requirements of 

Rule 4702 shall be considered to be an emission control technique and shall therefore, 
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be exempt from BACT and offsets requirements of District Rule 2201 provided that all 

other requirements of Rule 2201 are met. 

New Section 4.5 – Exemption for Stationary Engines Rated 25-50 bhp 

New Section 4.5 would be added to rule language to help clarify that the new 

requirements for stationary engines rated between 25 and 50 bhp include the point of 

sale requirement and the one time reporting requirement only. No other rule 

requirements are applicable to these engines at this time. The addition of stationary 

engines rated between 25 and 50 bhp have been presented to stakeholders as a point 

of sale requirement, with a one-time reporting requirement. Comments received from 

stakeholders pointed out that rule language could be misunderstood or misinterpreted; 

specifically, that the Sections 5.9 and 6.2.3 would be applicable to these engines. It 

was never the District’s intention to require small engines to be subject to these two 

Sections of the rule. Therefore, to help clarify rule requirements, and District intentions 

regarding the addition of stationary engines rated between 25-50 bhp to rule language, 

Section 4.5 would be added to rule language. 

4. Section 5.0 Requirements 

New Section 5.1 – IC Engines Rated Between 25 and 50 Brake Horsepower 

New Section 5.1 would establish the requirements for spark-ignited engines and 

compression-ignited engines rated at 25 to 50 bhp that are used exclusively in non-AO. 

These small engines are already regulated under the existing federal Standards of 

Performance. The provision is a point of sale provision and prohibits a person from 

selling, or offering for sale, engines rated at 25 to 50 bhp unless the engines meet the 

requirements and emission limits specified in the Code of Federal Regulation Title 40 

Part 60 (40 CFR 60) Subpart IIII (Standards of Performance for Stationary Compression 

Ignition Internal Combustion Engines) and 40 CFR 60 Subpart JJJJ (Standards of 

Performance for Stationary Spark Ignition Internal Combustion Engines) for the year 

that the engine is purchased. The provision is intended to ensure that more polluting 

engines are not sold to another person or entity if cleaner small engines that meet the 

current NSPS standards are available in the market. District staff has removed the 

terms “solicit the operation, supplying, and install” from this provision. Because this 

provision is a point of sale provision it does not affect the leasing of these engines 

because the ownership of the engine would remain with the lessor until such time as the 

lessor chooses to sell the engine; at that time, this provision would apply. 

This provision regulates engines by attrition rather than requiring the operator to install 

additional emission control system on existing engines as is the case for engines 

greater than 50 bhp. Over time, the non-AO engines between 25 and 50 bhp will be 

replaced with the cleanest-burning engines available and the replacement happens at a 

time of the operator’s choosing, since the operator elects when to replace a given 

engine. If there is no cleaner engine available, meaning that the federal emission limits 

haven’t changed since the engine was manufactured, the engine can change hands and 
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continue to operate within the Valley because the engine is the cleanest version 

available. Conversely, if there is a cleaner federal emission standard than the standard 

at the time the engine was manufactured, rather than continuing to have the older, 

dirtier engine continuing to operate, but at a different Valley location, the District is 

proposing that the older engine be retired or retrofitted to meet the latest standard. The 

proposed requirement, as written, is a win-win situation for both operators and Valley air 

quality because it provides continuous air quality improvement through normal engine 

turnover as well as operator flexibility by allowing the operator, not the District, to 

determine when to replace an engine. 

Additionally, the proposed rule amendments require the current owner of non-AO small 

engines operated in commercial, industrial, and institutional facilities to submit a onetime report to the District which includes information on the number of engines, location 

of each engine, engine manufacturer, model designation and engine serial number, 

engine bhp, fuel type and consumption rate, ignition type and combustion type, purpose 

of the engine, and daily operating schedule. The purpose of the report is to allow the 

District to improve the emission inventory for this category. It is important to note that 

the District intends to use the existing emission inventory gathering methodology to 

obtain this information from stakeholders. This will minimize any impacts to the 

facilities. 

Section 5.2 – Engines Rated Greater than 50 Brake Horsepower 

Section 5.2 specifies emission limits/standards for non-AO and AO spark-ignited 

engines and compression-ignited engines greater than 50 bhp. 

1.) Section 5.2.1 – Existing Emission Concentration Limits 

Section 5.2.1 would be reorganized for purposes of clarification and simplification of rule 

language. The existing emission limits for spark-ignited engines used in AO would be 

relocated to Section 5.2.3 of the rule. The existing non-AO limits will remain in effect 

until new emission limits become effective. 

2.) New Section 5.2.2 – Non-AO Spark-Ignited Engine Emission Concentration 

Limits 

Section 5.2.2 would specify the emission concentration limits for non-AO spark-ignited 

engines greater than 50 bhp, effective pursuant to the compliance schedule specified in 

Section 7.5. In the September 9, 2010 version of the draft rule amendments that were 

presented at the first public workshop, District staff proposed 11 ppmv NOx limit for all 

engines in this category. However, after considering the comments and 

recommendations from stakeholders and the Citizens Advisory Group of Industry 

(CAGI), District staff is proposing the NOx emission limits that take into account the 

differences between engines used in different applications. Table 1 summarizes the 

proposed emission limit changes. The limits are in concentration units of parts per 

million by volume on a dry basis (ppmvd), corrected to 15% oxygen. 
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Table 1 – Current and Proposed NOx Limits (in ppmvd corrected to 15% oxygen) 

Engine Type Current Limit Proposed Limit 

Rich-Burn Engines 

A. Waste Gas Fueled Engine 50 50 

B. Cyclic Loaded, Field Gas Fueled 50 50 

C. Limited Use Engine ---- * 25 

D. Rich-Burn Engine, not listed above 25 or 

96% reduction 

11 

Lean-Burn Engines 

E. Two-Stroke, Gaseous Fueled, 

 < 100 hp Engine 

75 or 

90% reduction 

75 

F. Limited Use Engine --- * 65 

G. Lean-Burn Engine used for gas 

compression 

--- * 65 or 93% reduction 

H. Lean-Burn Engine, not listed above 65 or 

90% reduction 

11 

* Limited-use engines and “lean-burn engines used for gas compression” are not categories in the 

current rule. They are currently subject to the applicable “not listed above” emission limits.

Due to the heat content variability of waste gas, NOx control can be problematic for 

engines fired on waste gas, therefore, District staff is proposing no amendments to the 

NOx emission concentration limit for waste gas fueled engines. 

Cyclic-loaded, field gas fueled engines can achieve some level of control, but not the 

very stringent control that can be imposed on engines that operate in a narrow range of 

loads. The exhaust gas temperature of cyclic loaded engines varies as a function of the 

engine load. Catalyst chemistry depends on a minimum temperature to be effective. 

When the cyclic load engine is operating in an engine load range that the exhaust gas is 

in the catalyst’s effective range, the emissions are well-controlled, but as the engine 

cycles out of this range, NOx control is less. Eventually, the exhaust gas temperature 

can be too low for any effective control. For this reason, District staff is proposing no 

amendments to the NOx limit for cyclic loaded field-gas fueled engines. 

Two-stroke, gaseous fueled engines between 50 hp and 100 hp would remain at the 

current NOx emission level. There is no technology that will allow a lower NOx level. 

The proposed amendments create a new category of engines that operate less than 

4,000 hours per year. This category was created based on the cost effectiveness of 

installing additional catalyst for these engines compared to engines that have higher 

utilization. These engines will be designated as “limited-use” engines. This is not to 

imply that the proposed amendments leave the engines as uncontrolled. The NOx 

concentration limit for limited-use rich-burn engines would be 25 ppmv NOx, which is 

the current emission limit for rich-burn engines. The NOx emissions foregone resulting 

from not lowering the existing NOx limit of 25 ppmv to 11 ppmv for the limited use 

engines is about 0.004 tons/day as shown in Appendix C of the Final Draft Staff Report. 
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Based on the District Permit Services database, there are no lean-burn engines 

currently operating less than 4,000 hours per year in the District. However, District staff 

is proposing to include this limited-use category of engines in order to provide operators 

with the option of limiting their engine usage so as not to retrofit with an expensive SCR 

system, in exchange for a reduction in their current emissions level. 

Lean-burn engines used in gas compression would be another new category created by 

the proposed rule. In general, these engines operate over a wide range of loads. As 

noted in the EPA’s technical support document (see Appendix F), these engines 

fluctuate over a broad range of conditions making SCR use problematic. For this 

reason, District staff proposes that the category of lean-burn engine used for gas 

compression be created with a NOx control as a percent reduction over the uncontrolled 

emission factor. Based on a review of the Permit-to-Operate for these engines, the 

majority of the operators choose the percent reduction option rather than the 65 ppmvd 

emission limit. 

Although District staff is leaving certain types of engines at their current numeric 

emission limits, for most engines the proposed rule removes the percent reduction as 

an alternative limit. As currently enforced, the operators with the percent reduction are 

assuming that the input to the control device is an uncontrolled engine. The percent 

reduction option when converted from pounds NOx per MMBtu to ppmvd at 15% 

oxygen is equal to or greater than the proposed numeric limit, therefore, removing the 

percent reduction option will not increase emissions from the targeted engine. 

3.) VOC and CO Emission Limits 

The September 2010 draft rule contained a CO limit of 500 ppmv and 30 ppmv VOC 

limit. Stakeholders recommended leaving the existing 2,000 ppmv CO and 250/750 

VOC limits in place. The Engine Manufacturers Association (EMA) commented that 

they do not believe reductions are achievable in practice for all stationary engine 

systems particularly for existing engines under varied operating and field conditions. 

EMA stated that for spark-ignited engines, there is a known relationship between 

emissions of NOx, VOC, and CO, in that as the engine is adjusted to reduce NOx, the 

VOC and CO emissions will increase. Efforts to adjust the engine to reduce VOC and 

CO emissions would result in an increase in NOx emissions. District staff contacted 

South Coast AQMD staff to determine if the current 30 ppmv VOC in South Coast 

AQMD’s Rule 1110.2 (Emissions from Gaseous - and Liquid-Fueled Engines) is being 

achieved. District staff has found that there are several variances that have been 

approved by South Coast AQMD Hearing Board allowing a temporary regulatory relief 

from the 30 ppmv VOC limit until such time that an alternate limit, which is an allowable 

provision of South Coast AQMD Rule 1110.2, could approved by their Executive Officer. 
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Based on stakeholders’ recommendations and results of the South Coast AQMD 

variances, District staff believes that it is appropriate to not change the existing VOC 

limits in Rule 4702. Likewise, the current CO limit of 2,000 ppmv would not be changed. 

Keeping the existing VOC and CO emission limits in the current rule would allow engine 

manufacturers and emission control system manufacturers to have the much-needed 

flexibility to be able to achieve much lower NOx emissions under varying field operating 

conditions and applications. 

4.) Section 5.2.2.1 – Spark-Ignited Non-AO Engine Compliance Requirements 

New Section 5.2.2.1 specifies requirements that non-AO engines shall comply with. 

This new section includes a requirement to comply with emission limits for NOx, CO, 

and VOC, as well as SOx control requirements and Monitoring requirements. 

5.) Section 5.2.2.2 – Annual Fee Option 

Section 5.2.2.2 allows operators of non-AO spark-ignited engines the option to pay 

annual fees in lieu of complying with new NOx limits. The District would take the fees 

generated by the annual fee option to fund other emission-reducing projects that would 

get equivalent reductions. Operators would remain subject to current NOx, CO, and 

VOC emission concentration limits. To further clarify, if an operator elects to use the fee 

payment option, the current emission limits would remain in place for these engines. 

This provision prevents existing engines that are included in a fee payment program 

from increasing their emissions above the current emission limits. Including this 

provision fulfills an EPA requirement called “anti-backsliding,” meaning changes to a 

rule cannot allow operators to increase their emissions above whatever is currently in 

place. Previous draft versions of the rule intended for this provision to be in place but 

did not clarify that in the rule language. Amendments have been made to the language 

to clarify this requirement. Operators that choose the fee option would also remain 

subject to the new SOx control and monitoring requirements of sections 5.7 and 5.10. 

6.) Section 5.2.2.3 – Spark-Ignited Non-OA Engines AECP Option 

This new Section 5.2.2.3 provides a provision for operators to participate in the 

alternative emission control plan pursuant to Section 8.0 in lieu of complying with the 

emission limits on an engine-by-engine basis. This provision provides operators 

another opportunity for flexibility in complying with rule requirements while still enabling 

the District to achieve it’s goals of reducing emissions in the Valley. 

7.) New Section 5.2.3 - AO Spark-Ignited Engine Emission Limits 

Section 5.2.3 requirements were originally combined with the non-AO spark ignited 

engines in Section 5.1.1 of the previously adopted version of this rule. For improved 

clarity of rule requirements, the AO engine emission limits have been moved to the new 

Section 5.2.3. There are no proposed amendments to the emission limits for AO 

engines for this rule-amending project. As published in the Federal Register, EPA 
SAN JOAQUIN VALLEY UNITIFED AIR POLLUTION CONTROL DISTRICT 

Final Staff Report: Rule 4702 (Internal Combustion Engines) August 18, 2011 

 13 Final Staff Report with Appendices

 For Revised Proposed Amendments to Rule 4702 

determined that the requirements of AO engines, as added to Rule 4702, to be, 

“consistent with EPA regulations, and relevant policy and guidance regarding 

enforceability, BACM/BACT, RACM/RACT, and SIP relaxations.”1

 Additionally, the 

Technical Support Document (TSD) published in August 2007 for the Proposed 

Rulemaking and District Final Rule for the California SIP for Rule 4702 states 

“Submitted Rule 4702 continues to implement BACM/BACT and other SIP approval 

criteria for stationary internal combustion engines. In addition, these revisions satisfy 

SJVAPCD’s commitment to apply BACT-level controls to agricultural engines, 

consistent with its Amended 2003 PM-10 Plan. Because the criteria for BACM/BACT 

are stricter than for RACT, by meeting BACT requirements submitted Rule 4702 also 

fulfills RACT.” 2

As illustrated by the dates of the EPA actions to approve the Rule 4702 as RACT, 

spark-ignited AO engines have only recently been required to comply with rule 4702 

and are in the first generation of rule requirements. It is important to note that AO 

engines are currently in the middle of the most recent compliance strategy and these 

engines are still in the process of coming into compliance with new standards with 

compliance dates ranging from January 2009 through January 2015. 

Additionally, as illustrated in Appendix D of Rule 4570 (Confined Animal Facilities), 

amended in October 2010, the agriculture community cannot absorb the costs of 

additional controls, nor can they pass those costs onto the consumer because the 

agricultural industry competes in a global economy where prices are not determined by 

the individual farmers. By comparison, non-AO engine emission limits were first 

adopted in 2003; meaning that operators with non-AO engines have had an opportunity 

to get a return on their investment. District staff will re-evaluate potential emission 

reductions from AO engines as part of future plan control measures and rule projects. 

8.) New Section 5.2.4 – AO and Non-AO Certified Compression-Ignited Engine 

Emission Limits 

The certified and non-certified compression ignited engines are currently combined in 

the rule. District staff has separated the certified and non-certified compression ignited 

engines to improve rule clarity. No changes are proposed for these engines. 

The June 22, 2011 version of draft rule amendments to Rule 4702 did not have draft 

amendments to Section 2.b of Table 4 – Emission Limits/Standards and Compliance 

Schedule for Compression-Ignited Internal Combustion Engines. However, the 

proposed amendments published on the District web page on July 19, 2011 amended 

 

1

 Revisions to the California State Implementation Plan, San Joaquin Valley Air Pollution Control District 

and Sacramento Metropolitan Air Quality management District, 73 Fed. Reg. 7, pp. 1818 – 1822. (2008, 

January 10). 

2

 Technical Support Document for EPA’s Notice of Proposed Rulemaking and Direct Final Rule for the 

California State Implementation Plan San Joaquin Valley Unified Air Pollution Control District Rule 4702, 

Internal Combustion Engines – Phase 2. (August 2007). 
SAN JOAQUIN VALLEY UNITIFED AIR POLLUTION CONTROL DISTRICT 

Final Staff Report: Rule 4702 (Internal Combustion Engines) August 18, 2011 

 14 Final Staff Report with Appendices

 For Revised Proposed Amendments to Rule 4702 

Section 2.b of Table 4 to remove this requirement from proposed rule requirements. 

This language was removed with the intention of clarifying rule requirements by 

simplifying rule language with the deletion of this section of the table. Upon further 

reflection, District staff feel that while deleting this language does not change rule 

requirements it could possibly confuse stakeholders; therefore, District staff have 

amended the proposed language to once again include this section in Table 4. It is 

important to note that the act of not deleting this requirement does not change the 

intention or requirements of rule language. 

New Section 5.6 – Annual Fee Option and Calculations 

New Section 5.6 provides the operator of a non-AO spark-ignited engine the option to 

pay an annual fee in lieu of complying with new NOx emission limits. This section 

details the calculation of emissions and fees for this option. Section 5.6.1.3 contains the 

calculation for determining total emissions of the unit for determining the annual fee. 

The Proposed Rule contains an updated version of the equation from the draft version 

that was presented to the public during the public workshop process. The intention of 

the updated equation was to simplify and clarify these calculations. Staff has further 

reviewed this version of the equation and determined that it contained a mathematical 

error. Staff has since revised the equation to correct the error, this corrected version is 

in the Revised Proposed Rule. This change in equation is for the sole purpose of 

clarifying the calculation and ensuring accuracy when calculating the total emissions of 

the unit when determining the annual fee. 

The fees continue to be based on the total annual NOx emissions for the unit. The 

District intends to use the fees collected by this program to acquire equivalent emission 

reductions from other sources. Details of the program itself will be sent to EPA when 

the program is initiated. Currently, the District does not take State Implementation Plan 

(SIP) credit for emissions reductions achieved through fee payment programs and 

related monetary incentive programs. The District has been collaborating with U.S. 

EPA and ARB to formalize a mechanism to provide SIP credit for emissions reductions 

from such programs. Since this work is still in progress, the District is not taking SIP 

credit from the Rule 4702 fee payment program at this time, but will continue to 

collaborate with EPA to allow for SIP credit from this component of Rule 4702 in the 

future. 

Not taking SIP credit for NOx emission reductions does not affect either the Ozone Plan 

attainment strategy nor does it affect the District’s 2008 PM2.5 attainment strategy 

because the control measure for amending Rule 4702 did not include any specific 

amount of emission reductions. The emission reduction analysis in Appendix B of this 

staff report is based on each engine complying with the rule through the installation of 

NOx emission control technology. The District staff expects that the emission 

reductions associated with the fee payment option will be higher than by requiring 

installation of individual control technology. 
SAN JOAQUIN VALLEY UNITIFED AIR POLLUTION CONTROL DISTRICT 

Final Staff Report: Rule 4702 (Internal Combustion Engines) August 18, 2011 

 15 Final Staff Report with Appendices

 For Revised Proposed Amendments to Rule 4702 

New Section 5.7 – Sulfur Oxide (SOx) Control Requirements 

The rule would limit SOx emissions through fuel choice. For non-AO engines, these 

fuels are widely available. Although the proposed sections limit the sulfur in the 

engine’s fuel, for SIP purposes, the District is not taking any credit for SOx emission 

reductions associated with the rule modifications because it is expected that all 

operators are already compliant with the requirement. Although SOx is a precursor to 

PM2.5, the control measure in the PM2.5 Plan did not commit the District to any SOx 

reduction; therefore, the attainment date is not adversely affected by not taking SIP 

credit for the potential SOx emission reductions. 

New Section 5.10 – SOx Emissions Monitoring Requirements 

New Section 5.10 outlines the necessary monitoring for operators selecting nonstandard fuels or elect to comply through a SOx emission control technology. 

Operators utilizing standard fuels would have no monitoring or testing requirements. 

5. Section 6.0 Administrative Requirements 

Section 6.1 – Emission Control Plan 

Section 6.1 would be rewritten to clarify existing rule requirements regarding engines 

that are required to have emission control plans. This proposed amendment does not 

change the requirement or meaning of this section of the rule. Also, language would be 

added to this section that allows operators with no changes to their emission control 

plan to submit a letter stating that there are no changes rather than having to submit the 

entire plan. District staff agreed with a stakeholder who stated that preparing an 

emission control plan is time-consuming and is redundant if the existing emission 

control plan is already adequate. The proposed change would streamline compliance 

for certain operators of existing engines. 

Existing Section 6.3 – Compliance Testing 

Section 6.3.1 would be rewritten to clarify existing rule requirements pertaining to 

compliance testing. This proposed amendment does not change the requirement or 

meaning of this section of the rule. 

Section 6.4 – Test Methods 

1.) Section 6.4.7 – SOx Test Methods 

Section 6.4.6 would be added in order to specify the test methods for determining SOx, 

total sulfur as hydrogen sulfide, sulfur content of liquid fuel, and calculation method for 

SOx control efficiency. 
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2.) Section 6.4.7 – Higher Heating Value Test Methods 

Section 6.4.7 would be added to specify the allowable test methods for determining a 

fuel’s higher heating value. These test methods were added to complement the 

addition of SOx requirements. 

Section 6.5 – Inspection and Monitoring (I&M) Plan 

Section 6.5 would be rewritten to clarify rule requirements pertaining to the submission 

of I&M plans. This proposed amendment does not change the requirement or meaning 

of this section of the rule. Also, language would be added to this section to allow 

operators with no changes to the facility’s I&M Plan to submit a letter to that effect rather 

than submitting a new plan. This provision affords operators a streamlined process 

when there are no changes to the facility’s current I&M Plan. 

6. Section 7.0 – Compliance Schedule 

District staff has reviewed the compliance schedules and, for the sake of clarity and 

simplification of rule language, expired language has been removed and the section has 

been renumbered as appropriate. 

New Section 7.5 – Non-AO Spark Ignited Engine 

This section provides the compliance schedule for the operator of a non-AO sparkignited engine subject to the rule to comply with. The September 2010 version of the 

draft rule had a single compliance date. In response to stakeholder comments, the draft 

compliance date has been amended and now a phased-in compliance schedule is 

proposed. Additional discussions with stakeholders yielded a further refinement - 

operators with more engines have a longer period of time to come into compliance, 

starting in 2014 and ending in 2017. The longer compliance schedule recognizes that 

operators with more engines might have some logistical issues in bringing so many 

engines into compliance in a short amount of time, while recognizing the District’s 

commitment to expedite air quality benefits as committed to by the Governing Board 

with the dual path strategy. 

Table 2 below shows the proposed compliance schedule. It is important to note that the 

division of compliance date requirements in Table 2 is specific to the amount of engines 

per stationary source and not to the amount of engines owned by an operator. For 

example, an operator that owns 12 engines with five engines at one facility and the 

other seven engines at another facility would not have the 2017 compliance timeline as 

allowed for operators with at least 12 engines at a stationary source; because all the 

engines are not at one stationary source, rather than one location. 
SAN JOAQUIN VALLEY UNITIFED AIR POLLUTION CONTROL DISTRICT 

Final Staff Report: Rule 4702 (Internal Combustion Engines) August 18, 2011 

 17 Final Staff Report with Appendices

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Table 2 – Proposed Compliance Schedule for Non-AO Spark Ignited Engines 

Engines to be in Compliance at a 

Stationary Source 

Emission 

Control Plan 

Authority to 

Construct and 

Inspection and 

Monitoring Plan 

Full 

Compliance

Single Engine at a stationary 

source 

1/1/12 1/1/13 1/1/14 

Operator with at least two engines, but less than 12 engines at a stationary source 

33% or more of the engines 7/1/12 1/1/13 1/1/14 

66% or more of the engines 7/1/12 1/1/14 1/1/15 

100% of the engines 7/1/12 1/1/15 1/1/16 

Operator with at least 12 engines at a stationary source 

25% or more of the engines 7/1/12 1/1/13 1/1/14 

50% or more of the engines 7/1/12 1/1/14 1/1/15 

75% or more of the engines 7/1/12 1/1/15 1/1/16 

100% of the engines 7/1/12 1/1/16 1/1/17 

New Section 7.6 – Annual Fee Payment Option 

The owner of a Non-AO spark-ignited engine who elects to pay annual NOx emission 

fees to the District in lieu of complying with the new NOx emission limits would be 

required to submit an Emission Control Plan which includes the information specified in 

new Section 7.6.1 by July 1, 2012. The owner would be required to pay the total annual 

fee to the District no later than June 30 of each year for the NOx emissions of the 

previous calendar year. Payment would continue annually until the engine either is 

permanently removed from use in the Valley and the Permit-to-Operate is surrendered, 

or the operator demonstrates compliance with the proposed rule’s Table 2 emission 

limits. 

C. Implications of the Federal Stationary Reciprocating Internal Combustion 

Engine (RICE) Requirements 

Although the District has some of the most stringent rules in the nation, the federal EPA 

also creates rules to limit emissions. One such rule that affects stationary internal 

combustion engines is 40 CFR 63 Subpart ZZZZ (National Emissions Standards for 

Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines). 

Also called a Maximum Achievable Control Techniques (MACT), the MACT divides the 

engines into several groups and has different provisions for the different engine groups 

depending on whether the facility where the engine is located is a major or area 

Hazardous Air Pollutants (HAPs) source, spark-ignited or compression-ignited, rich-burn 

or lean-burn, etc. For some engines, the MACT requires periodic maintenance only. 

For other engines, there are specific emission limits, source testing, and monitoring 

requirements. There are either CO or formaldehyde emission limits for certain larger 

spark-ignited engines. It is these engines that are of interest for this rule project. 
SAN JOAQUIN VALLEY UNITIFED AIR POLLUTION CONTROL DISTRICT 

Final Staff Report: Rule 4702 (Internal Combustion Engines) August 18, 2011 

 18 Final Staff Report with Appendices

 For Revised Proposed Amendments to Rule 4702 

There are some engines that are in compliance with the MACT’s low emission limits for 

CO/formaldehyde without an add-on control system. An existing engine that does not 

meet the emission limits would need to be modified, which usually means installing an 

emission control system containing an oxidation catalyst. The installation of the 

oxidation catalyst would be in addition to any equipment necessary to meet the Revised 

Proposed Rule 4702’s proposed NOx limit. 

In addition to the potential to have a two-catalyst emission control system, the MACT 

compliance schedule is a little ahead of schedule for Revised Proposed Rule 4702. All 

spark-ignited engines at area HAPs sources that are subject to the RICE engine MACT 

must be in full compliance with standards by May 2013. As noted earlier, some engines 

are already in compliance with the MACT’s CO/formaldehyde limits and no retrofit would 

be required to meet the MACT standard. The compliance schedule for Revised 

Proposed Rule 4702 is tiered, meaning that, for operators with multiple engines, 

compliance deadlines are phased in over three or four years beginning in 2014. In a 

worst case scenario, operators could make modifications to meet the RICE engine 

MACT in 2013, and then need to make more modifications in 2014. District staff 

believes that by making operators aware of the changes in the District’s rule soon 

enough would allow the operators to combine MACT and District rule retrofits to 

minimize downtime and costs. 

Stakeholders contacted about how they were going to meet the RICE engine MACT 

stated that they were early in their assessment process and hadn’t fully determined their 

course of action. In general, operators are concerned about the engineering design 

challenges as well as the operational complexity inherent in a two-catalyst emission 

control system. 

V. EMISSION REDUCTION ANALYSIS 

District staff queried the District Permit Services Database for all engines, and then 

manually sorted the engines into one of three categories: emergency standby, richburn, and lean-burn. No analysis was done for emergency standby engines because 

the proposed rule amendments do not affect this type of engine. Of the remaining 

engines, District staff determined that out of 326 rich-burn engines, only 160 engines 

would be required to reduce their NOx emissions. For lean-burn engines, District staff 

found a total of 97 lean-burn engines, of which 62 have permit limits higher than the 

proposed rule limits. Based on the assumptions used, District staff estimates that the 

proposed changes in the rule limits for non-AO spark-ignited engines would lead to 

approximately 1.4 tons per day of NOx emission reductions. 

Currently, the District does not take State Implementation Plan (SIP) credit for 

emissions reductions achieved through fee payment programs and related monetary 

incentive programs; even though such innovative programs will be critical in helping the 

Valley meet both current and future air quality standards. The District has been 
SAN JOAQUIN VALLEY UNITIFED AIR POLLUTION CONTROL DISTRICT 

Final Staff Report: Rule 4702 (Internal Combustion Engines) August 18, 2011 

 19 Final Staff Report with Appendices

 For Revised Proposed Amendments to Rule 4702 

collaborating with U.S. EPA and ARB to formalize a mechanism to provide SIP credit for 

emissions reductions from such programs. Since this work is still in progress, the 

District is not taking SIP credit from the Rule 4702 fee payment program at this time, but 

will continue to collaborate with EPA to allow for SIP credit from this component of Rule 

4702 in the future 

It is the District’s experience that, when an emission limit is reduced, a small percentage 

of operators will choose to replace their IC engines with electric motors rather than 

retrofit with an emission control system. Based on past experience with engine rule 

amendments, some of the 222 affected engines replaced by electric motors. It would 

be speculative, to determine which engines would electrified, therefore the following 

emission reduction analysis does not include an estimate for NOx reductions associated 

with electrification scenarios. All affected engines are analyzed as if they will add NOx 

controls rather than replace the engine with an electric motor. 

District staff will not claim emission reductions for State Implementation Plan (SIP) 

purposes as part of this rule project. However, District staff will use the 1.4 tons per day 

of NOx reductions in order to estimate cost effectiveness. A summary of the analysis 

results is shown in Table 3 and details of the calculations are in Appendix B of this staff 

report. 

Table 3 – Summary of Estimated NOx Reductions Used for Cost Effectiveness 

Calculations 

Engine Type 

Total 

Permitted 

Engines 

Number 

Affected 

Engines 

Total Rated 

Power 

(bhp) 

Estimated 

NOx 

Reductions 

(tpy) 

Estimated 

NOx 

Reductions 

(tpd) 

Rich-Burn 326 160 80,738 131.5 0.36 

Lean-Burn 97 62 123,886 390.9 1.07 

Total 423 222 204,624 522.4 1.43 

VI. COST EFFECTIVENESS ANALYSIS 

Proposed Rule 4702 would implement low NOx limits for non-AO spark-ignited engines. 

These engines burn natural gas, gas from waste products or field gas. It is the District’s 

experience that, when an emission limit is reduced, a small percentage of operators will 

choose to replace their IC engines with electric motors rather than retrofit with an 

emission control system. Based on this past experience, there would be at least 

several engines replaced by electric motors. It would be speculative to determine which 

engines would electrified, therefore the following compliance costs and cost 

effectiveness analysis do not include any cost-of-electrification scenarios. 

The estimated total annual cost to retrofit 222 engines is a range between $12.3 million 

and $27.1 million annually. This range in total annual cost illustrates the variability in 
SAN JOAQUIN VALLEY UNITIFED AIR POLLUTION CONTROL DISTRICT 

Final Staff Report: Rule 4702 (Internal Combustion Engines) August 18, 2011 

 20 Final Staff Report with Appendices

 For Revised Proposed Amendments to Rule 4702 

facilities, engines, and changes that would need to be made in order to comply with 

proposed limits. It is important to note that District staff understand that each facility is 

unique and as such, faces unique challenges when making changes to engines, 

operations, and even changes in building structures, in order to comply with new 

requirements. 

Absolute cost effectiveness is the estimated total annual cost divided by the estimated 

emission reductions. Table 4 shows the costs and the results of the cost effectiveness 

analysis for engines greater than 50 bhp. District staff estimates that operators will 

need to retrofit a total of 222 engines at an annual cost between $12.3 million and $27.1 

million. For rich-burn engines, the estimated cost effectiveness is $29,600 per ton NOx 

removed. For lean-burn engines, the absolute cost effectiveness for this rule project is 

between $21,600 and $59,300. Taking the rule amendments as a whole, the cost 

effectiveness is between $23,600 and $51,800 per ton NOx removed. If all operators 

choose the fee payment option, cost effectiveness for all engines is $17,500 per ton 

NOx removed. Table 4 summarizes the compliance costs and cost effectiveness for 

both the situation where all operators elect to retro fit engines to meet the NOx emission 

limits and the situation where all of the operators elect fee payment in lieu of 

compliance. 

Table 4 – Summary of Compliance Costs and Cost Effectiveness to Retrofit All 

Engines 

All Operators Retrofit Their Engines 

Rich-Burn Lean-Burn Overall 

Number Affected Engines 160 62 222

Total Cost ($/yr) a lower cost

higher cost

--- 

$3,900,000

$8,400,000 - 

$23,200,000 

$12,300,000 - 

$27,100,000

Cost Effectiveness b ($/ton NOx) --- 

$29,600

$21,600 - 

$59,300 

$23,600 - 

$51,800

All Operators Elect Alternative Compliance Fee 

Rich-Burn Lean-Burn Overall 

Number Affected Engines 160 62 222

Total Cost ($/yr) a $1,700,000 $7,500,000 $9,100,000

Cost Effectiveness b ($/ton NOx) $12,600 $19,100 $17,500 a

 Rounded to nearest $100,000; Total may be off due to rounding 

b Rounded to nearest $100

The incremental cost effectiveness is the difference in cost between successively more 

effective controls. For engines operating at least 6,750 hours annually, the NOx 

emission concentration limits are the most stringent available. For this reason, no 

incremental cost effectiveness analysis can be done because there is no more stringent 

option available for these engines. 
SAN JOAQUIN VALLEY UNITIFED AIR POLLUTION CONTROL DISTRICT 

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 21 Final Staff Report with Appendices

 For Revised Proposed Amendments to Rule 4702 

The incremental cost effectiveness for requiring engines operating less than 4,000 

hours per year to retrofit to meet a lower NOx limit was evaluated. Incremental cost 

effectiveness cannot be directly compared to the absolute cost effectiveness, but allows 

comparison between successively more stringent compliance options. In this case, the 

incremental cost effectiveness analysis focuses on limited-use engines and evaluates 

the difference between keeping the current NOx emission limit and requiring a lower 

NOx limit for these engines. The incremental cost effectiveness for limited-use engines 

is about $183,800 per ton additional NOx removed. 

Details of the compliance costs and the cost effectiveness analysis are contained in 

Appendix C of this staff report. 

VII. SOCIOECONOMIC IMPACT ANALYSIS 

Pursuant to California Health and Safety Code (CH&SC) 40728.5(a), “Whenever a 

district intends to propose the adoption, amendment, or repeal of a rule or regulation 

that will significantly affect air quality or emissions limitations, that agency shall, to the 

extent data are available, perform an assessment of the socioeconomic impacts of the 

adoption, amendment, or repeal of the rule or regulation.” As part of the District’s 

socioeconomic analysis process, a meeting of operators and other interested parties 

was convened in September 2010 to discuss compliance costs and possible business 

responses to the proposed amendments. Using information gathered during Focus 

Group meeting and public comment period, a draft of the socioeconomic impact 

analysis report was presented during the June 2011 workshop for the rule. The 

socioeconomic impact analysis was performed by Applied Development Economics, 

Inc. (ADE) and is included with the Final Draft Staff Report as Appendix D. The rule 

affects both private sector businesses and public agencies like water districts and cities 

or counties. For the private sector industries as a group (25 businesses), the costs 

have been evaluated in relation to financial operating ratios and fall below the level of 

significance for socioeconomic impacts. As such, it is anticipated that the industries can 

absorb these costs or pass a portion of the costs on to their customers without 

significantly affecting the businesses’ viability. Four of the affected businesses meet the 

criteria as small businesses in the State of California. These businesses have been 

evaluated separately but the proposed fee levels are low enough to avoid as significant 

socioeconomic impact for these businesses as well. 

For the public water and wastewater agencies, the fees range from 0.3 percent up to 

1.1 percent of agency operating revenues. In the short term, it is likely these fees could 

be absorbed by the agencies, but would be included in future rate increases, some of 

which may need voter approval. 
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The impact analysis report includes an evaluation of the economic impact on affected 

small businesses and compares it to the impact to affected businesses overall. Of the 

25 entities across the various private sector industries, three are small businesses. The 

estimated fees for each of these businesses were evaluated separately and the ratio of 

costs to net profits does not exceed the threshold of significance. The affected small 

businesses are not disproportionately affected by the proposed rule amendments. 

VIII. ENVIRONMENTAL IMPACT ASSESSMENT 

Pursuant to the California Environmental Quality Act (CEQA), District staff has reviewed 

the project for potential environmental impacts resulting from implementation of the 

revised proposed amendments to Rule 4702 (Internal Combustion Engines). 

Implementation of this project is expected to result in NOx emission reductions of about 

522.4 tons/year (1.43 tons/day) as evaluated in Appendix B. Thus, the District has 

determined that implementation of the proposed amendments to Rule 4702 would result 

in a positive impact on air quality. 

In addition, the District also assessed potential changes in greenhouse gas (GHG) 

emissions which would occur as a result of implementation of the proposed 

amendments. It was assumed that rich burn engines affected by this rule amendment 

already are equipped with non-selective catalytic reduction systems (NSCR). As such, 

there will be no GHG increase attributed to the rich-burn engine category at this time 

because there is no change to the control technology. 

For purposes of assessing greenhouse gas impacts, District staff assumes that 

operators of the lean-burn engines affected by the proposed rule amendments do not 

currently have SCR units, but will install SCR units as the control technology of choice 

in order to meet the rule’s stringent NOx emission limits. 

 SCR control technology can reduce the fuel efficiency of an engine by as much as 

5%, meaning that 5% more fuel must be burned in order to have the same power 

output.

 Utilizing 5% as a conservatively high assumption for an engine's power penalty due 

to the use of an SCR system, and conservatively applying that power loss to the 

total rated horsepower of all engines affected by the rule changes (a total of 123,886 

bhp), there is an equivalent 6,194 bhp increase required to maintain current power 

levels.

 Using a conversion factor to convert the additional 6,194 hp to carbon dioxide 

equivalents (metric ton CO2-e), it is estimated that the installation of 62 SCR units 

will increase GHG emissions by 15,200 metric ton-CO2e/year.

 Compared to the installation of a SCR control system, electrification (i.e., replacing a 

fossil fuel burning engine with an electric motor) as a method of compliance has the 

potential to offset any increases in GHG emissions. The District identified the 
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number of engines subject to Rule 4702 that would need to electrify in order to 

offset the potential increase in GHG emissions. The assessment demonstrated 

electrification of two to three engines would reduce the net increase in GHG 

emissions. See Appendix B for more details on the calculations. 

 Based on prior rule projects, electrification of two to three engines is a plausible 

compliance response to the rule requirements, thereby offsetting the increased GHG 

emissions from the SCR. 

Taking the above analysis as a whole, District staff concludes that implementation of the 

proposed revisions would have a less than cumulative significant impact on global 

climate change. 

District staff concludes that there is no substantial evidence in the whole record before 

the District that the revised proposed amendments to Rule 4702 would cause any 

adverse effects on the environment. Pursuant to CEQA Guidelines §15063 (a), District 

staff has prepared an Initial Study and Negative Declaration for the project. Upon 

approval of the proposed amendments by the District’s Governing Board, District staff 

will file a Notice of Determination with each County Clerk within the boundaries of the 

District, CEQA Guidelines § 15075(d). 

IX. RULE CONSISTENCY ANALYSIS 

Pursuant to CH&SC Section 40727.2, staff has prepared a rule consistency analysis 

that compares the elements of Rule 4702 with the corresponding elements of other 

District rules and federal regulations and guidelines that apply to the same type of 

equipment or source category. The analysis is discussed in Appendix E of this staff 

report. District staff has concluded that Proposed Rule 4702 is not in conflict with nor 

inconsistent with other District rules nor is Proposed Rule 4702 in conflict with nor 

inconsistent with federal policy, rules, or regulations governing the same source 

category. 

X. OTHER ANALYSES 

A. Reasonably Available Control Technology (RACT) Analysis 

Sections 182(b)(2) and 182(f) of the federal Clean Air Act require ozone nonattainment 

areas to implement RACT for sources that are subject to Control Techniques Guidelines 

(CTG) documents issued by EPA and for “major sources” of VOCs and NOx, which are 

ozone precursors. RACT can be defined as devices, systems, process modifications, or 

other apparatus or techniques that are reasonably available, taking into account the 

necessity of imposing such controls in order to attain and maintain a national ambient 

air quality standard (NAAQS); the social, environmental, and economic impact of such 
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controls; and alternative means of providing for attainment and maintenance of such a 

standard. These control techniques, which are defined in EPA guidelines for limiting 

emissions from existing sources in nonattainment areas, are adopted and implemented 

for nonattainment areas by state analysis. The following paragraphs evaluate the 

requirements of Proposed Rule 4702 in light of the RACT definition outlined previously. 

In August 2007, EPA published the Technical Support Document (TSD)3 for the current 

version of Rule 4702 in conjunction with EPA’s full approval of the rule for inclusion into 

the State Implementation Plan (SIP). As published in the Federal Register, EPA 

determined that the requirements of AO engines, as added to Rule 4702, to be, 

“consistent with EPA regulations, and relevant policy and guidance regarding 

enforceability, BACM/BACT, RACM/RACT, and SIP relaxations.”4 Additionally, the TSD 

published in August 2007 for the Proposed Rulemaking and District Final Rule for the 

California SIP for Rule 4702 states “Submitted Rule 4702 continues to implement 

BACM/BACT and other SIP approval criteria for stationary internal combustion engines. 

In addition, these revisions satisfy SJVAPCD’s commitment to apply BACT-level 

controls to agricultural engines, consistent with its Amended 2003 PM-10 Plan. 

Because the criteria for BACM/BACT are stricter than for RACT, by meeting BACT 

requirements submitted Rule 4702 also fulfills RACT.” Since the full approval of the 

current version of Rule 4702 by EPA, emissions control technology for stationary 

internal combustion engines has not changed significantly, and the proposed 

amendments to Rule 4702 to make existing emissions limitations more stringent clearly 

exceed RACT. 

1. Emergency Engines and Low-Use Engines 

District staff is not proposing any changes to the exemption requirements for emergency 

standby engines and low-use engines. The existing requirements are consistent with 

ARB RACT/BARCT Determination for Spark-Ignited Engines and ARB Airborne Toxics 

Control Measures (ATCM). In addition, the ATCM is already being implemented 

through the District’s process for issuing Permits to Operate. The exemptions as 

outlined in the current rule represent RACT for these sources. 

2. AO Spark-Ignited Engines 

There are no proposed amendments to the existing emission limits for AO spark-ignited 

engines because AO engines have only recently been required to comply with rule 4702 

and are in the first generation of rule requirements. It is important to note that AO 

 

3

 Technical Support Document for EPA’s Notice of Proposed Rulemaking and Direct Final Rule for the 

California State Implementation Plan – San Joaquin Valley Unified Air Pollution Control District Rule 4702 

(Internal Combustion Engine – Phase 2), August 2007. 

4

 Revisions to the California State Implementation Plan, San Joaquin Valley Air Pollution Control District 

and Sacramento Metropolitan Air Quality management District, 73 Fed. Reg. 7, pp. 1818 – 1822. (2008, 

January 10). 
SAN JOAQUIN VALLEY UNITIFED AIR POLLUTION CONTROL DISTRICT 

Final Staff Report: Rule 4702 (Internal Combustion Engines) August 18, 2011 

 25 Final Staff Report with Appendices

 For Revised Proposed Amendments to Rule 4702 

engines are currently in the middle of the most recent compliance strategy and these 

engines are still in the process of coming into compliance with new standards. 

As stated earlier, in August 2007, EPA published the TSD5 for the current version of 

Rule 4702 in conjunction with EPA’s full approval of the rule for inclusion into the SIP. 

As published in the Federal Register, EPA determined that the requirements of AO 

engines, as added to Rule 4702, to be, “consistent with EPA regulations, and relevant 

policy and guidance regarding enforceability, BACM/BACT, RACM/RACT, and SIP 

relaxations.”6 Additionally, the TSD published in August 2007 for the Proposed 

Rulemaking and District Final Rule for the California SIP for Rule 4702 states 

“Submitted Rule 4702 continues to implement BACM/BACT and other SIP approval 

criteria for stationary internal combustion engines. In addition, these revisions satisfy 

SJVAPCD’s commitment to apply BACT-level controls to agricultural engines, 

consistent with its Amended 2003 PM-10 Plan. Because the criteria for BACM/BACT 

are stricter than for RACT, by meeting BACT requirements submitted Rule 4702 also 

fulfills RACT.” 7

As previously stated, owners of AO engines have just recently installed emission control 

systems to meet the current emission limits effective January 2009. The control 

systems included a 3-way catalytic converter, air/fuel ratio controller, and oxygen 

sensor. The District is still evaluating the effectiveness and implementation issues 

associated with this type of control system, which have faced challenges due to the 

nature of agricultural engine installations, including remote locations, fluctuations in gas 

pressures, and unattended operations, which make it more difficult to constantly monitor 

the emissions level during day-to-day operation of the engines. The District will be 

evaluating the long-term effectiveness of the currently installed emission control system 

for possible future rule amendments on AO engines. 

As determined by EPA in 2007, District staff believes that the existing Rule 4702 

emission limits for agricultural engines meets RACT. 

3. Compression Ignited Engines (AO and non-AO) 

The existing emission limits for compression-ignited engines apply to both nonagricultural and agricultural engines. It should be noted that certified Tier 1 or Tier 2 

diesel engines are required to comply with EPA certified Tier 4 by January 1, 2015 or 12 

 

5

 Technical Support Document for EPA’s Notice of Proposed Rulemaking and Direct Final Rule for the 

California State Implementation Plan – San Joaquin Valley Unified Air Pollution Control District Rule 4702 

(Internal Combustion Engine – Phase 2), August 2007. 

6

 Revisions to the California State Implementation Plan, San Joaquin Valley Air Pollution Control District 

and Sacramento Metropolitan Air Quality management District, 73 Fed. Reg. 7, pp. 1818 – 1822. (2008, 

January 10). 

7

 Technical Support Document for EPA’s Notice of Proposed Rulemaking and Direct Final Rule for the 

California State Implementation Plan San Joaquin Valley Unified Air Pollution Control District Rule 4702, 

Internal Combustion Engines – Phase 2. (August 2007). 
SAN JOAQUIN VALLEY UNITIFED AIR POLLUTION CONTROL DISTRICT 

Final Staff Report: Rule 4702 (Internal Combustion Engines) August 18, 2011 

 26 Final Staff Report with Appendices

 For Revised Proposed Amendments to Rule 4702 

years after installation date, whichever is later. Non-certified diesel engines that are 

required to meet either Tier 3 or Tier 4 depending on the engine size and its operating 

hours have just began complying with the existing emission limits early this year, and 

some of the larger engines will need to comply by mid-2011. Engines greater than 500 

hp that operate at least 1,000 hours annually were required to meet 80 ppmv NOx last 

January 1, 2008 or by January 1, 2010, if the owner has an agreement to replace the 

diesel engine with electric motor. As determined by EPA in 2007, District staff believes 

that the existing Rule 4702 emission limits for agricultural engines meets RACT. 

4. Limited-Use Non-AO Spark Ignited Engines (Rich-Burn and Lean-Burn) 

District staff evaluated stationary engines that operate less than 4,000 hours annually 

and compared the cost effectiveness for the limited-use engines and full-time use 

engines. Since limited-use engines have fewer emissions on an annual basis, the cost 

effectiveness for a limited-use engine is higher than for a full-time engine. For this 

reason, the proposed rule includes a separate category for limited-use engines that 

keeps the current emission limit, which, as discussed earlier, meets RACT. 

5. Waste Gas Fueled Non-AO Spark Ignited Rich-Burn Engines 

The current NOx limit in Rule 4702 for non-AO waste gas fueled rich-burn engines is 50 

ppmv (at 15% O2) or 90 percent reduction. Although SCAQMD Rule 1110.2 specifies a 

NOx limit of 11 ppmv for landfill gas or digester gas fired engines effective July 1, 2012, 

Rule 1110.2 includes a provision to complete a technology assessment by July 2010 

and that the limit will only be implemented if the result of SCAQMD’s technology 

assessment that is confirms that 11 ppmv is indeed achievable. In a recent telephone 

conversation with South Coast AQMD staff, District staff has found that the technology 

assessment would not be completed until next year. Therefore, District staff is not 

proposing any change to the current limit for non-AO waste gas fueled rich-burn 

engines until such time that South Coast AQMD’s technology assessment confirms that 

it is technologically and economically feasible to achieve the rule limit. As determined 

by EPA in 2007, District staff believes that the existing Rule 4702 emission limits for 

waste gas-fueled non-AO spark-ignited rich-burn engines meets RACT. 

6. Cyclic Loaded Field Gas Fueled Non-AO Spark Ignited Rich-Bun Engines 

As noted earlier in this report, cyclic-loaded, field gas fueled engines can achieve some 

level of control, but not the very stringent control that can be imposed on engines that 

operate in a narrow range of loads. The exhaust gas temperature of cyclic loaded 

engines varies as a function of the engine load. Catalyst chemistry depends on a 

minimum temperature to be effective. When the cyclic load engine is operating in an 

engine load range that the exhaust gas is in the catalyst’s effective range, the emissions 

are well-controlled, but as the engine cycles out of the “sweet spot,” NOx control is less. 
SAN JOAQUIN VALLEY UNITIFED AIR POLLUTION CONTROL DISTRICT 

Final Staff Report: Rule 4702 (Internal Combustion Engines) August 18, 2011 

 27 Final Staff Report with Appendices

 For Revised Proposed Amendments to Rule 4702 

Eventually, the exhaust gas temperature can be too low for any effective control. For 

this reason, District staff believes that the current emission limit fulfills RACT. . As 

determined by EPA in 2007, District staff believes that the existing Rule 4702 emission 

limits for cyclic-loaded field gas-fueled non-AO spark-ignited rich-burn engines meets 

RACT. 

7. 2-Stroke Engines Less than 100 hp Non-AO Spark Ignited Lean-Burn 

Engines 

There is no technology for these engines that will allow a lower NOx level. District staff 

believes that the current emission limit for 2-stroke engines less than 100 hp fulfills 

RACT. 

8. Lean-Burn Engine Used For Gas Compression 

Most large natural gas-fired lean-burn IC engines in the region are in natural gas 

distribution and storage service and these engines experience frequently changing load 

conditions. In the technical support document for the EPA’s 2003 NOx SIP call, the 

EPA stated that there is an insufficient basis currently to conclude that SCR is an 

appropriate technology for the large lean-burn engines used for gas compression. The 

proposed emission limit is achievable through low-NOx combustion technology, which 

includes changes to the engine’s timing, enhanced control of the air-fuel ratio and other 

changes that lower NOx emissions. For this reason, and given the prior approval of the 

existing emissions limitation as RACT for this category, District staff believes that the 

proposed emission limit for these engines fulfills RACT for this source category. 

9. Non-AO Spark Ignited Engines, Not Listed (Rich-Burn and Lean-Burn) 

The proposed emission limit of 11 ppmvd for non-AO spark ignited engines is more 

stringent than RACT since the engines in question would be required to install 

advanced add-on controls in order to meet the proposed limit. The proposed emission 

limit goes beyond RACT for this source category. 

10. Consideration for Prohibitory Rules in Other California Air Districts: South 

Coast AQMD Rule 1110.2 (Emissions from Gaseous - and Liquid-Fueled 

Engines) 

In considering what benchmarks to use for RACT, it is important to evaluate other 

emission limits that have been imposed on the same source category. District staff 

reviewed South Coast AQMD Rule 1110.2, which covers the same source category as 

District Rule 4702. South Coast AQMD Rule 1110.2 has stringent NOx, CO, and VOC 

emission limits for internal combustion engines. 
SAN JOAQUIN VALLEY UNITIFED AIR POLLUTION CONTROL DISTRICT 

Final Staff Report: Rule 4702 (Internal Combustion Engines) August 18, 2011 

 28 Final Staff Report with Appendices

 For Revised Proposed Amendments to Rule 4702 

While on the surface it would appear that the South Coast AQMD rule is more stringent, 

the medium and large operators in the South Coast Air Basin are most likely part of the 

South Coast RECLAIM program and therefore, not meeting the emission limits outlined 

in the South Coast AQMD rule. All facilities that emit more than a certain amount of 

pollution are required to be in the RECLAIM program. Certain companies receive 

emission allocations every year. Each allocation is good for 12 months. The portion of 

the allocation not needed to offset the operator’s own emissions can be sold to other 

companies. If the operator does not receive an emission allocation, they must buy 

emission credits from operators with unused emission allocations. In this way, the 

RECLAIM program is similar to a cap-and-trade program. At this time, the District is not 

planning a RECLAIM-type program for this source category. Instead, a fee payment 

program in lieu of complying with the very stringent NOx limits is proposed. District staff 

believes that the current rule limits fulfill RACT, as evidenced by the recent approval of 

the current version of Rule 4702 by EPA. The proposed limits are beyond RACT and 

fulfill the state mandate for all feasible measures. 

11. Conclusion 

Since the previous rule was determined to meet RACT and this amendment further 

strengthens the rule requirements, this rule is expected to establish requirements well 

beyond RACT, and thus satisfies RACT. 

B. Consideration for the Condensable Fraction of PM2.5 

Certain high-temperature processes emit gaseous pollutants that rapidly condense into 

particle form in the ambient air. After January 1, 2011, areas that are nonattainment for 

the National Ambient Air Quality Standard (NAAQS) for PM2.5 are to consider the 

condensable fraction of directly emitted PM2.5 for purposes of establishing the 

emissions limits for: 

 Reasonable Further Progress (RFP), in which an area shows continuous 

reductions of directly emitted PM2.5 and precursors, with sufficient emissions 

reductions to demonstrate attainment by the applicable deadline

 Reasonably Available Control Technology (RACT) and Reasonably Available 

Control Measures (RACM), in which a nonattainment area shows that it is 

adopting technologies and measures reasonably available, considering technical 

and economic feasibility; sufficient to demonstrate expeditious attainment; and 

meet RFP. (Code of Federal Regulations Title 40 Section 51.1002(c))
SAN JOAQUIN VALLEY UNITIFED AIR POLLUTION CONTROL DISTRICT 

Final Staff Report: Rule 4702 (Internal Combustion Engines) August 18, 2011 

 29 Final Staff Report with Appendices

 For Revised Proposed Amendments to Rule 4702 

The District established emissions limits for its attainment, RFP, and RACT/RACM 

demonstrations in the PM2.5 Plan for the PM2.5 NAAQS as set by EPA in 1997. The 

District continues to evaluate condensable particulates and other directly emitted PM2.5 

to improve its PM2.5 emissions inventory for future attainment plan efforts. 

Specific emission reduction targets for Rule 4702 were neither included in, nor does this 

action impede, the emissions limits set in the PM2.5 Plan. The District is not currently 

aware of significant uncontrolled condensable PM2.5 emissions or related condensable 

PM2.5 emissions control technologies for the sources affected by this amendment. 

Therefore, the District has satisfied any applicable requirement to consider condensable 

particulates from this source at this time. 

XI. REFERENCES 

1. California Air Resources Board: Determination of Reasonably Available Control 

Technology and Best Available Retrofit Control Technology for Stationary SparkIgnited Internal Combustion Engines. November 2001. 

2. South Coast Air Quality Management District: Rule 1110.2 (Emissions from 

Gaseous- and Liquid- Fueled Engines). February 1, 2008. 

3. South Coast Air Quality Management District: Final Staff Report for Proposed 

Amended District Rule 1110.2 (Emissions from Gaseous- and Liquid- Fueled 

Engines). December 2007. 

4. U.S. Environmental Protection Agency: Alternative Control Techniques Document – 

NOx emissions from Stationary Reciprocating Internal Combustion Engines. EPA453/R-93-032. July 1993. 

5. U.S. Environmental Protection Agency: Code of Federal Regulation Title 40 Part 51 

Subpart U (Economic Incentive Programs) 

6. U.S. Environmental Protection Agency: Code of Federal Regulations Title 40 

Section 51 Subpart Z (Provisions for Implementation of PM2.5 National Ambient Air 

Quality Standards). 

7. U.S. Environmental Protection Agency: Revisions to the California State 

Implementation Plan, San Joaquin Valley Air Pollution Control District and 

Sacramento Metropolitan Air Quality management District, 73 Fed. Reg. 7, pp. 1818 

– 1822. January 10, 2008. 

8. U.S. Environmental Protection Agency: Technical Support Document for EPA’s 

Notice of Proposed Rulemaking and Direct Final Rule for the California State 
SAN JOAQUIN VALLEY UNITIFED AIR POLLUTION CONTROL DISTRICT 

Final Staff Report: Rule 4702 (Internal Combustion Engines) August 18, 2011 

 30 Final Staff Report with Appendices

 For Revised Proposed Amendments to Rule 4702 

Implementation Plan – San Joaquin Valley Unified Air Pollution Control District Rule 

4702 (Internal Combustion Engine – Phase 2). August 2007. 

9. U.S. Environmental Protection Agency: Stationary Reciprocating Internal 

Combustion Engines Technical Support Document for NOx SIP Call. October 2003