CALIFORNIA AIR RESOURCES BOARD 

SIP COMPLETENESS CHECKLIST 

(Electronic Format) 

*** TO BE COMPLETED BY DISTRICT AND RETURNED TO ARB *** 

All rules submitted to the EPA as State Implementation Plan (SIP) revisions must be supported by certain information 

and documentation for the rule packages to be deemed complete for review by the EPA. Rules will not be evaluated for 

approvability by the EPA unless the submittal packages are complete. To assist you in determining that all necessary 

materials are included in rules packages sent to the ARB for submittal to the EPA, please fill out the following form and 

include it with the rule package you send ARB. See the ARB's Guidelines on the Implementation of the 40 CFR 51, 

Appendix V, for a more detailed explanation than is provided here. Adopted rules and rule amendments should be 

checked against U.S. EPA's Guidance Document for Correcting Common VOC & Other Rule Deficiencies (Little Blue 

Book, August 21, 2001) to ensure that they contain no elements which will result in disapproval by EPA. 

District: Imperial County Air Pollution Control District

Rule No: 202

Rule Title: Exemptions

Date Adopted or Amended: October 10, 2006

ADMINISTRATIVE MATERIALS 

Note: All documents should be in electronic format. Items that have signatures, initials, or stamps may be scanned. 

 Not 

Attached Attached N/A

 COMPLETE COPY OF THE RULE: Provide an unmarked copy of the entire 

rule as adopted or amended by your District Board. 

 UNDERLINE AND STRIKEOUT COPY OF THE RULE: If an amended rule, 

provide a complete copy of the rule indicating in underline and strikeout format 

all language which has been added, deleted, or changed since the rule was 

last adopted or amended. 

 COMPLETE COPY OF THE REFERENCED RULE(S): For any rule which 

includes language specifically referencing another rule, a copy of that other 

rule must also be submitted, unless it has already been submitted to EPA as 

part of a previous SIP submittal. 

 PUBLIC NOTICE EVIDENCE: Include a copy of the local newspaper clipping 

certification(s), stating the date of publication, which must be at least 30 days 

before the hearing. As an alternative, include a copy of the actual published 

notice of the public hearing as it appeared in the local newspaper(s). In this 

case, however, enough of the newspaper page must be included to show the 

date of publication. The notice must specifically identify by title and number 

each rule adopted or amended. 

 RESOLUTION/MINUTE ORDER: Provide the Board Clerk certified resolution 

or minute order. This document must include certification that the hearing 

was held in accordance with the information in the public notice. It must also 

list the rules that were adopted or amended, the date of the public hearing, 

and a statement of compliance with California Health and Safety Code 

Sections 40725-40728 (Administrative Procedures Act). 

 PUBLIC COMMENTS AND RESPONSES: Submit copies of written public 

comments made during the notice period and at the public hearing. Also 

submit any written responses prepared by the District staff or presented to the 

District Board at the public hearing. A summary of the public comments and 

responses is adequate. If there were no comments made during the notice 

period or at the hearing, please indicate N/A to the left. 
 

5/1/2002 

CALIFORNIA AIR RESOURCES BOARD 

SIP COMPLETENESS CHECKLIST 

(Electronic Format)

TECHNICAL MATERIALS 

 Not 

Attached Attached N/A

 RULE EVALUATION FORM: See instructions for completing the Rule 

Evaluation Form and the accompanying sample form. 

 NON-EPA TEST METHODS: Attach all test methods that are referenced in 

your rule that do not appear in 40 CFR 51, 60, 61, 63, or have not been 

previously submitted to EPA. EPA methods used in other media such as 

SW846 for solid waste are not automatically approved for air pollution 

applications. Submittal of test methods that are not EPA-approved should 

include the information and follow the procedure described in Region 9’s “Test 

Method Review & Evaluation Process.” 

 MODELING SUPPORT: Provide if appropriate. In general, modeling support is 

not required for VOC and NOx rules to determine their impacts on ozone 

levels. Modeling is required where a rule is a relaxation that affects large 

sources (> 100 TPY) in an attainment area for SO2, directly emitted PM10, 

CO, or NOx (for NO2 purposes). In cases where EPA is concerned with the 

impact on air quality of rule revisions which relax limits or cause a shift in 

emission patterns in a nonattainment area, a reference back to the approved 

SIP will be sufficient provided the approved SIP accounts for the relaxation 

and provided the approved SIP used the current EPA modeling guidelines. If 

current EPA modeling guidelines were not used, then new modeling may be 

required. 

 ECONOMIC AND TECHNICAL JUSTIFICATION FOR DEVIATIONS FROM 

EPA POLICIES: The District staff report or other information included with the 

submittal should discuss all potential relaxations or deviations from RACT, 

RACM, BACT, BACM, enforceability, attainment, RFP, or other relevant EPA 

requirements. This includes, for example, demonstrating that exemptions or 

emission limits less stringent than the presumptive RACT (e.g., a CTG) meet 

EPA’s 5 percent policy, and demonstrating that all source categories 

exempted from a RACM/BACM rule are de minimus according to EPA’s 

RACM/BACM policy. 

 ADDITIONAL MATERIALS: Provide District staff reports and any other 

supporting information concerning development of the rule or rule changes. 

This information should explain the basis for all limits and thresholds 

contained in the rule. 
CALIFORNIA AIR RESOURCES BOARD 

APCD/AQMD RULE EVALUATION FORM -- Page 1

(Electronic Format) 

I. GENERAL INFORMATION

District: Imperial County Air Pollution Control District

Rule No(s): 202 Date adopted/Amended/Rescinded: October 10, 2006

Rule Title(s): Exemptions

Date Submitted to ARB: March 26, 2007

If an Amended Rule, Date Last Amended (or Adopted): 09/14/1999

Is the Rule Intended to be Sent to the U.S. EPA as a SIP Revision? Yes No (If No, do not complete remainder of form)

District Contact: Reyes Romero Phone Number: (760) 482-4606 E-mail Address: reyesromero@imperialcounty.net

Narrative Summary of New Rule or Rule Changes: New Rule Amended Rule 

The amendments to Rule 202 Exemptions directly affects "Agricultural Sources." The amendments identify an 

exemption to permit requirements. In particular, "Agricultural Operations" was replaced by "Agricultural Sources." 

The identifed exemption includes stationary combustion agricultural sources with less than a combined actual 

emissions of one half the applicable threshold for a major source. In addition, those CAF's not meeting the 

definition of a LCAF are exempt from permit requirements.

Pollutant(s) Regulated by the Rule (Check): ROG (NOx) SO2 

 (CO) PM TAC (name):N/A

II. EFFECT ON EMISSIONS

Complete this section ONLY for rules that, when implemented, will result in quantifiable changes in emissions. Attach reference(s) for emission 

factor(s) and other information. Attach calculation sheet showing how the emission information provided below was determined. 

Net Effect on Emissions: Increase Decrease N/A 

Emission Reduction Commitment in SIP for this Source Category: N/A

Inventory Year Used to Calculate Changes in Emissions: N/A Area Affected: N/A

Future Year Control Profile Estimate (Provide information on as many years as possible): 

N/A
CALIFORNIA AIR RESOURCES BOARD 

APCD/AQMD RULE EVALUATION FORM -- Page 2

(Electronic Format) 

Baseline Inventory in the SIP for the Control Measure: N/A

Emissions Reduction Commitment in the SIP for the Control Measure: N/A

Revised Baseline Inventory (if any): N/A

Revised Emission Reduction Estimate (if developed): N/A

Note that the district’s input to the Rule Evaluation Form will not be used as input to the ARB’s emission forecasting and 

planning. 

III. SOURCES/ATTAINMENT STATUS

District is: Attainment Nonattainment Split 

Approximate Total Number of Small (<100 TPY) Sources Affected by this Amendment: N/A

Percent in Nonattainment Area: N/A% 

Number of Large (> 100 TPY) Sources Controlled: N/A Percent in Nonattainment Area: N/A% 

Name(s) and Location(s) (city and county) of Large (> 100 TPY) Sources Controlled by Rule (Attach additional sheets as 

necessary): B/A

IV. EMISSION REDUCTION TECHNOLOGY

Does the Rule Include Emission Limits that are Continuous? Yes No 

If Yes, Those Limits are in Section(s) N/A of the Rule. 

Other Methods in the Rule for Achieving Emission Reductions are: N/A

V. OTHER REQUIREMENTS

The Rule Contains: 

Emission Limits in Section(s): N/A Work Practice Standards in Section(s): N/

Recordkeeping Requirements in Section(s): N/A Reporting Requirements in Section(s): N/A
CALIFORNIA AIR RESOURCES BOARD 

APCD/AQMD RULE EVALUATION FORM -- Page 3

(Electronic Format) 

5/1/2002 

3

VI. IMPACT ON AIR QUALITY PLAN

 No Impact Impacts RFP Impacts attainment 

Discussion: 
MINUTE ORDER 

OF 

AIR POLLUTION 

CONTROL BOARD 

THE BOARD OF SUPERVISORS OF THE COUNTY OF IMPERIAL, STATE OF CALIFORNIA, on a motion 

by Supervisor : MARUCA , second by Supervisor : WATT 

and approved by tne tollowlng roll call vote; 

AYES : CARRILLO,GROGAN,MARUCA,WATT,LEIMGRUBER 

Date: October 10, 2006 

NAYES : NONE 

ABSTAINED : NONE 

EXCUSED OR ABSENT : NONE 

Book: 342 

IN REFERENCE TO : 

Approved associated Findings in the staff reports for each of the above rules. 

Page: I5O 

X-File 1: X-File 2: X-File 3: 

File #: I7O3 

epartment: APCD 

X-File 4: 

. . Topic: Staff Reports X-TO~~C: Approved Fmdl;g,s5 5=-...._;_.., 

,>?La i."i;-: kbkl;.T/l~! 

M.O.#: l8 I 

2nd Page: 

,.. . -,-- 

CC: IXI File Behavioral Health Health Sheriff-Coroner 

IXI AgIAPCD CEO ICCED Social Services 

Assessors County Counsel il Planning Other ... I MAR 2 2 2007 

IXI Auditor County Property I7 Public Works 1 .,,, ,, , ,,Tan.n 

, 

I 
- MINUTE ORDER 

0 F 

AIR POLLUTION 

CONTROLBOARD 

THE BOARD OF SUPERVISORS OF THE COUNTY OF IMPERIAL, STATE OF CALIFORNIA, on a motion 

by Supervisor : WYATT , second by Supervisor : MARUCA 

and approved by tne ro~~owlng roll call vote; 

Date: October 10, 2006 

AYES : CARRILLO,GROGAN,MARUCA,~T,LEIMGRUBER 

NAYES: 

ABSTAINED : NONE 

EXCUSED OR ABSENT : NONE 

IN REFERENCE TO : 

Book: 342 

Rule 202 - Exemptions 

Topic: Rule 202 x-~opic: Permits required ,,-, 

j ,rri,w~-~---- ,*- hA[.Lzl:\-) 7. ,t 

CC: H File Behavioral Health I7 Health Sheriff-Coroner I -===\&+&I8 L? !cCL@1 1; 

AgIAPCD CEO ICCED Social Services 

Assessors IJ County Counsel I7 Planning IJ Other ... 1; I k4AR 2 2 2007 

Auditor County Property I7 Public Works i 1 .,,.,.,......- 

I 

I! "16f rWLLte I IW(\ 1, %WTF?OL , . DISTRICT. j -. 

Page: 14' 

X-File 1: X-File 2: X-File 3: 

File #: I7O3 

epartment: APCD 

X-File 4: 

M.O.#: 18 c 

2nd Page: 
Imperial County Air Pollution Control District Draft Rule 202 

202-1 

RULE 202. EXEMPTIONS 

(Adopted prior to 11/19/85; revised 9/7/93, 9/14/99,C/C/C) 

A. An Authority to Construct or Permit to Operate shall not be required for any process, article, 

machine, Equipment, or other contrivance listed in Section E unless: 

A.1 The process, article, machine, Equipment, or other contrivance is subject to New 

Source Performance Standards (NSPS) or National Emission Standards for 

Hazardous Air Pollutants (NESHAPS) or a Source specific prohibitory rule, or 

A.2 The process, article, machine, Equipment, or other contrivance emits, in quantities 

determined to be appropriate for review by the Air Pollution Control Officer, 

substances identified as Toxic Air Contaminants or which are under review as 

candidate Toxic Air Contaminants by the California Air Resources Board, or 

A.3 The Air Pollution Control Officer makes a determination that a permit shall be 

required because the Equipment may not operate in compliance with all Air Pollution 

Control District rules and regulations. 

B. An Authority to Construct or Permit to Operate shall not be required for any process, article, 

machine, Equipment, or other contrivance with uncontrolled emissions of Affected Pollutants 

less than or equal to two pounds in any 24-hour period. 

C. An otherwise exempt piece of Equipment requires a permit if it is part of a process that 

requires a permit. 

D. Appropriate recordkeeping shall be required to verify and maintain any exemption. 

E. Unless otherwise specified in sections A or B, an Authority to Construct or Permit to Operate 

shall not be required for the following Equipment: 

E.1 Combustion and Heat Transfer Equipment 

E.1.a Internal Combustion Engines and Gas Turbines: Piston type internal 

combustion engines with a manufacturer's maximum continuous rating of 50 

brake horsepower (bhp) or less or gas turbine engines with a maximum heat 

input rate of 3 million British thermal units (Btu) per hour or less at ISO 

Standard Day Conditions. The ratings of all engines or turbines used within a 

Stationary Source will be accumulated to determine whether this exemption 

applies. 

E.1.b (reserved) 

E.1.c Steam generator, steam superheaters, water boilers, water heaters, steam 

cleaners, and closed indirect heat transfer systems which have a maximum 
Imperial County Air Pollution Control District Draft Rule 202 

202-2 

input heat rating of 5,000,000 Btu per hour (gross) or less and are equipped to 

be fired exclusively with Public Utilities Commission regulated natural gas, 

liquefied petroleum gas or any combination thereof. 

E.1.d Portable equipment holding a valid registration under the Statewide Portable 

Equipment Registration Program pursuant to Title 13, Article 5, Sections 

2450 - 2465 of the California Code of Regulations. 

E.2 Vehicles 

E.2.a Motor Vehicles as defined by the Vehicle Code of the State of California but 

not including any article, machine, Equipment, or other contrivance mounted 

on such vehicle, that would otherwise require a permit under the provisions 

of these rules and regulations. 

E.2.b Locomotives, airplanes and watercraft used to transport passengers or freight. 

This exemption is not intended to apply to Equipment used for the dredging 

of waterways or to Equipment used in pile driving adjacent to or in 

waterways. 

E.3 Residential Structures 

E.3.a Any structure designed for and used exclusively as a dwelling for not more 

than four families and any Incinerator used exclusively in connection with 

such a structure. 

E.4 Cooling Towers 

E.4.a. Water Cooling Towers that have a circulation rate of less than 10,000 gallons 

per minute and which are not used for cooling of process water, water from 

barometric jets or water from barometric condensers. 

E.5 Printing and Reproduction Equipment 

E.5.a Printing and related Coating or laminating Equipment not using more than 2 

gallons of graphic arts material per day. Graphic arts materials are any inks, 

Coatings, Adhesives, fountain solutions, thinners, retarders, or cleaning 

solutions used in printing or related Coating or laminating processes. (Does 

not include Equipment associated with wood flat stock Coating operations.) 

E.6 Food Processing 

E.6.a Equipment, excluding boilers, used in eating establishments or other retail 

establishments for the purpose of preparing food for human consumption. 
Imperial County Air Pollution Control District Draft Rule 202 

202-3 

E.6.b Mixers and blenders used in bakeries where the products are edible and 

intended for human consumption. Ovens at bakeries whose total production 

is less than 1,000 pounds of product per operating day. 

E.6.c Equipment used exclusively to grind, blend or package tea, cocoa, spices or 

roasted coffee and Control Equipment venting exclusively such Equipment. 

E.6.d Smokehouses for preparing food in which the maximum horizontal inside 

cross-section area does not exceed 20 square feet (or 2 square meters). 

E.6.e Barbecue Equipment. 

E.7 Plastic/Rubber Processing 

E.7.a General - The following uncontrolled Equipment or process, located at the 

same Stationary Source, using material containing ROCs, when aggregated 

emissions of ROCs from the Equipment or process do not exceed 5 pounds in 

any one day: 

- Foam manufacturing or application 

- Fiberglass reinforced plastic fabrication 

- Plastics manufacturing 

E.7.b Presses - Equipment used exclusively for extruding rubber products or plastic 

where no plasticizer or blowing agent is present, or for pelletizing polystyrene 

foam scraps except Equipment used to extrude or to pelletize acrylics, 

polyvinyl chloride, polystyrene, and their copolymers. 

E.7.c Ovens - Ovens used exclusively for the curing, softening, or annealing of 

plastics. Does not apply to ovens used to cure fiberglass reinforced plastics. 

E.8 Storage and Transfer Equipment 

E.8.a Unheated solvent dispensing containers with capacity not more than 250 

gallons. 

E.8.b Mobile Transport Tanks or delivery tanks or cargo tanks on vehicles for 

delivery of VOCs except Asphalt tankers used to transport and transfer hot 

Asphalt for roofing applications. 

E.8.c Equipment used exclusively for the storage of unheated Organic Material 

with an initial boiling point of 150 C (302 F) or greater, or with an organic 

vapor pressure of 5 mm Hg (0.1 psi) absolute or less at 21.1 C (70 F) as 
Imperial County Air Pollution Control District Draft Rule 202 

202-4 

determined by the following ASTM test methods: 

E.8.c.1 ASTM D 2879-86, "Standard Test Method for Vapor 

Pressure-Temperature Relationship and Initial Decomposition 

Temperature of Liquids by Isoteniscope" 

E.8.c.2 ASTM 1078-86, "Standard Test Method for Distillation Range of 

Volatile Organic Liquids" 

E.8.d Equipment used exclusively for the unheated underground storage of 23,000 

liters (6,077 gallons) or less of organic liquids with a vapor pressure of 77.5 

mm Hg (1.5 psi) absolute or less at actual storage conditions. Equipment 

used exclusively for the transfer to or from such storage of organic liquids 

with a vapor pressure of 77.5 mm Hg (1.5 psi) absolute or less at actual 

storage conditions. Vapor pressure to be determined by ASTM D 2879-86, 

"Standard Test Method for Vapor Pressure-Temperature Relationship and 

Initial Decomposition Temperature of Liquids by Isoteniscope". 

E.9 Surface Coating and Cleaning Operations 

E.9.a Application Equipment for architectural surface Coatings used for 

commercial or residential applications. Architectural surface Coating is 

defined as any Coating applied to stationary structures and their 

Appurtenances, to mobile homes, to pavements, or to curbs. 

E.9.b Unheated non-conveyorized, cleaning Equipment: (Does not include control 

enclosures) 

E.9.b.1 With an open surface area of 1.0 square meters (10.8 sq. feet) or less 

and an internal volume of 350 liters (92.5 gal.) or less, and 

E.9.b.2 Using only Organic Solvents with an initial boiling point of 160 C 

(302 F) or greater as determined by ASTM test method 1078-86, 

"Standard Test Method for Distillation Range of Volatile Organic 

Liquids", and 

E.9.b.3 Less than 25 gallons of solvent per year are lost to the Atmosphere 

from all such Equipment. Solvent lost shall not include solvent that 

is recycled or disposed of properly. Any Person claiming exemption 

pursuant to this subsection shall maintain adequate monthly records 

to substantiate their exempt status. 

E.9.c Surface Coating Equipment using a combined total of one gallon per day or 

less of Coating material and solvent. Coatings applied by means of 

non-refillable aerosol cans shall not be included in the daily usage 
Imperial County Air Pollution Control District Draft Rule 202 

202-5 

determination for purposes of determining the one gallon per day limit. 

E.9.d Surface Coating using non-refillable aerosol spray cans. 

E.10 Agricultural Operations Sources

E.10.a Stationary combustion agricultural sources with combined actual emissions 

 of less than one half of any applicable emissions threshold for a major source.

E.10.b Any confined animal facility that maintains on any one day less than 1,000

milk producing cows; or less than 3,500 beef cattle, calves, heifers, or other

cattle; or less than 100,000 turkeys or less than 650,000 chickens other than 

laying hens; or less than 650,000 laying hens; or less than 3,000 swine; or 

less than 15,000 sheep, lambs or goats; or less than 2,500 horses or less than 

650,000 ducks or less than 30,000 rabbits or other animals.

Any Equipment used in agricultural operations in the growing and/or harvesting of crops or 

the raising of fowl or animals, except that the district Board of any district which is, in whole 

or in part, south of the Sixth Standard Parallel South, Mount Diablo Base and Meridian, may 

require permits for the operation of orchard and citrus grove heaters. In no event shall a 

permit be denied an operator of such heaters if the heaters produce unconsumed solid 

carbonaceous matter at the rate of one gram per minute or less. 

E.11 Repairs or Maintenance 

Routine repairs or maintenance not involving structural changes to any Equipment 

for which a permit has been granted. 
Imperial County Air Pollution Control District Rule 202 

202-1 

RULE 202. EXEMPTIONS 

(Adopted prior to 11/19/85; revised 9/7/93, 9/14/99, 10/10/2006) 

A. An Authority to Construct or Permit to Operate shall not be required for any process, article, 

machine, Equipment, or other contrivance listed in Section E unless: 

A.1 The process, article, machine, Equipment, or other contrivance is subject to New 

Source Performance Standards (NSPS) or National Emission Standards for 

Hazardous Air Pollutants (NESHAPS) or a Source specific prohibitory rule, or 

A.2 The process, article, machine, Equipment, or other contrivance emits, in quantities 

determined to be appropriate for review by the Air Pollution Control Officer, 

substances identified as Toxic Air Contaminants or which are under review as 

candidate Toxic Air Contaminants by the California Air Resources Board, or 

A.3 The Air Pollution Control Officer makes a determination that a permit shall be 

required because the Equipment may not operate in compliance with all Air Pollution 

Control District rules and regulations. 

B. An Authority to Construct or Permit to Operate shall not be required for any process, article, 

machine, Equipment, or other contrivance with uncontrolled emissions of Affected Pollutants 

less than or equal to two pounds in any 24-hour period. 

C. An otherwise exempt piece of Equipment requires a permit if it is part of a process that 

requires a permit. 

D. Appropriate recordkeeping shall be required to verify and maintain any exemption. 

E. Unless otherwise specified in sections A or B, an Authority to Construct or Permit to Operate 

shall not be required for the following Equipment: 

E.1 Combustion and Heat Transfer Equipment 

E.1.a Internal Combustion Engines and Gas Turbines: Piston type internal 

combustion engines with a manufacturer's maximum continuous rating of 50 

brake horsepower (bhp) or less or gas turbine engines with a maximum heat 

input rate of 3 million British thermal units (Btu) per hour or less at ISO 

Standard Day Conditions. The ratings of all engines or turbines used within a 

Stationary Source will be accumulated to determine whether this exemption 

applies. 

E.1.b (reserved) 

E.1.c Steam generator, steam superheaters, water boilers, water heaters, steam 

cleaners, and closed indirect heat transfer systems which have a maximum 

input heat rating of 5,000,000 Btu per hour (gross) or less and are equipped to 
Imperial County Air Pollution Control District Rule 202 

202-2 

be fired exclusively with Public Utilities Commission regulated natural gas, 

liquefied petroleum gas or any combination thereof. 

E.1.d Portable equipment holding a valid registration under the Statewide Portable 

Equipment Registration Program pursuant to Title 13, Article 5, Sections 

2450 - 2465 of the California Code of Regulations. 

E.2 Vehicles 

E.2.a Motor Vehicles as defined by the Vehicle Code of the State of California but 

not including any article, machine, Equipment, or other contrivance mounted 

on such vehicle, that would otherwise require a permit under the provisions 

of these rules and regulations. 

E.2.b Locomotives, airplanes and watercraft used to transport passengers or freight. 

 This exemption is not intended to apply to Equipment used for the dredging 

of waterways or to Equipment used in pile driving adjacent to or in 

waterways. 

E.3 Residential Structures 

E.3.a Any structure designed for and used exclusively as a dwelling for not more 

than four families and any Incinerator used exclusively in connection with 

such a structure. 

E.4 Cooling Towers 

E.4.a. Water Cooling Towers that have a circulation rate of less than 10,000 gallons 

per minute and which are not used for cooling of process water, water from 

barometric jets or water from barometric condensers. 

E.5 Printing and Reproduction Equipment 

E.5.a Printing and related Coating or laminating Equipment not using more than 2 

gallons of graphic arts material per day. Graphic arts materials are any inks, 

Coatings, Adhesives, fountain solutions, thinners, retarders, or cleaning 

solutions used in printing or related Coating or laminating processes. (Does 

not include Equipment associated with wood flat stock Coating operations.) 

E.6 Food Processing 

E.6.a Equipment, excluding boilers, used in eating establishments or other retail 

establishments for the purpose of preparing food for human consumption. 

E.6.b Mixers and blenders used in bakeries where the products are edible and 

intended for human consumption. Ovens at bakeries whose total production 
Imperial County Air Pollution Control District Rule 202 

202-3 

is less than 1,000 pounds of product per operating day. 

E.6.c Equipment used exclusively to grind, blend or package tea, cocoa, spices or 

roasted coffee and Control Equipment venting exclusively such Equipment. 

E.6.d Smokehouses for preparing food in which the maximum horizontal inside 

cross-section area does not exceed 20 square feet (or 2 square meters). 

E.6.e Barbecue Equipment. 

E.7 Plastic/Rubber Processing 

E.7.a General - The following uncontrolled Equipment or process, located at the 

same Stationary Source, using material containing ROCs, when aggregated 

emissions of ROCs from the Equipment or process do not exceed 5 pounds in 

any one day: 

- Foam manufacturing or application 

- Fiberglass reinforced plastic fabrication 

- Plastics manufacturing 

E.7.b Presses - Equipment used exclusively for extruding rubber products or plastic 

where no plasticizer or blowing agent is present, or for pelletizing polystyrene 

foam scraps except Equipment used to extrude or to pelletize acrylics, 

polyvinyl chloride, polystyrene, and their copolymers. 

E.7.c Ovens - Ovens used exclusively for the curing, softening, or annealing of 

plastics. Does not apply to ovens used to cure fiberglass reinforced plastics. 

E.8 Storage and Transfer Equipment 

E.8.a Unheated solvent dispensing containers with capacity not more than 250 

gallons. 

E.8.b Mobile Transport Tanks or delivery tanks or cargo tanks on vehicles for 

delivery of VOCs except Asphalt tankers used to transport and transfer hot 

Asphalt for roofing applications. 

E.8.c Equipment used exclusively for the storage of unheated Organic Material 

with an initial boiling point of 150 C (302 F) or greater, or with an organic 

vapor pressure of 5 mm Hg (0.1 psi) absolute or less at 21.1 C (70 F) as 

determined by the following ASTM test methods: 

E.8.c.1 ASTM D 2879-86, "Standard Test Method for Vapor 

Pressure-Temperature Relationship and Initial Decomposition 
Imperial County Air Pollution Control District Rule 202 

202-4 

Temperature of Liquids by Isoteniscope" 

E.8.c.2 ASTM 1078-86, "Standard Test Method for Distillation Range of 

Volatile Organic Liquids" 

E.8.d Equipment used exclusively for the unheated underground storage of 23,000 

liters (6,077 gallons) or less of organic liquids with a vapor pressure of 77.5 

mm Hg (1.5 psi) absolute or less at actual storage conditions. Equipment 

used exclusively for the transfer to or from such storage of organic liquids 

with a vapor pressure of 77.5 mm Hg (1.5 psi) absolute or less at actual 

storage conditions. Vapor pressure to be determined by ASTM D 2879-86, 

"Standard Test Method for Vapor Pressure-Temperature Relationship and 

Initial Decomposition Temperature of Liquids by Isoteniscope". 

E.9 Surface Coating and Cleaning Operations 

E.9.a Application Equipment for architectural surface Coatings used for 

commercial or residential applications. Architectural surface Coating is 

defined as any Coating applied to stationary structures and their 

Appurtenances, to mobile homes, to pavements, or to curbs. 

E.9.b Unheated non-conveyorized, cleaning Equipment: (Does not include control 

enclosures) 

E.9.b.1 With an open surface area of 1.0 square meters (10.8 sq. feet) or less 

and an internal volume of 350 liters (92.5 gal.) or less, and 

E.9.b.2 Using only Organic Solvents with an initial boiling point of 160 C 

(302 F) or greater as determined by ASTM test method 1078-86, 

"Standard Test Method for Distillation Range of Volatile Organic 

Liquids", and 

E.9.b.3 Less than 25 gallons of solvent per year are lost to the Atmosphere 

from all such Equipment. Solvent lost shall not include solvent that 

is recycled or disposed of properly. Any Person claiming exemption 

pursuant to this subsection shall maintain adequate monthly records 

to substantiate their exempt status. 

E.9.c Surface Coating Equipment using a combined total of one gallon per day or 

less of Coating material and solvent. Coatings applied by means of 

non-refillable aerosol cans shall not be included in the daily usage 

determination for purposes of determining the one gallon per day limit. 

E.9.d Surface Coating using non-refillable aerosol spray cans. 

E.10 Agricultural Sources 
Imperial County Air Pollution Control District Rule 202 

202-5 

E.10.a Stationary combustion agricultural sources with combined actual emissions 

 of less than one half of any applicable emissions threshold for a major source. 

E.10.b Any confined animal facility that maintains on any one day less than 1,000 

milk producing cows; or less than 3500 beef cattle, calves, heifers, or other 

cattle; or less than 100,000 turkeys or less than 650,000 chickens other than 

laying hens; or less than 650,000 laying hens; or less than 3,000 swine; or 

less than 15,000 sheep, lambs or goats; or less than 2,500 horses or less than 

650,000 ducks or less than 30,000 rabbits or other animals. 

E.11 Repairs or Maintenance 

Routine repairs or maintenance not involving structural changes to any Equipment 

for which a permit has been granted. 
STATE OF CALIFORNIA I - -- 

AFFIDAVIT OF PUBLICATION 

(2015.5 C.C.P.) 

County of Imperial I 

This space is for the County Clerk's 

Filing Stamp: 

IMPERIAL VALLEY PRESS 

I am a resident of the County aforesaid; 

I am over the age of eighteen years, and 

not a party to or interested in the above 

entitled matter. I am the principal clerk* 

of the printer of the 

a newspaper of general circulation, 

printed and published daily in the City of 

El Centro, County of Imperial and which 

newspaper has been adjudged a 

newspaper of general circulation by the 

Superior Court of the County of Imperial, 

State of California! under the date of 

October 9, 1951, Case Number 26775; 

that the notice, of which the annexed is 

a printed copy, has been published~ineach regular and entire issue of said 

and n.ornnv ~u~pplement 

thereof on the following dates, to-wit: 

Proof of Publication of: 

all in the year 20& 

I certify (or declare) under penalty of 

perjury that the foregoing is true and 

correct. 

LEGAL ADVERTISEMENT , "," 

, .# IMPERIAL ,. .. CQUNW :.: AIR POLLUTION , \,!.. :: , ,', .. . I . ".L -.... :,. 

I NO~GE, ~FTPUBLIC HEARING:,FOR. +DOPTION 

DRGULAT~OM$OFT,HE IMPERIAL 

' . . , .:( , : . , I 

* Printer, Foreman of the Printer, or 

Principal Clerk of the Printer 

'The ~oar$i<f, t$ :impqial %gt!nTy Air ~oilution Contiol ~ist~~~~~iii$$"d.~c

pub(c~&~"gp.. '; ^;>.d:>l ..'. .- . .: : 

. .. 

. . i:i- .:.& r :,.. ":: ;:;; 

! consid%d5ptionhf revlslons to tee Flowihg district'.~ulei an~+~gu!$htiorlS: ::> : I , . : , . 'T' ? "' .. . . . , . , . , !? 

, , ; .?,> , ,.,. , $.,:?:; ,:.,: ., '?" .:: ', 

.' 1 Rrie dpli: ~kfi$$?~sj~,):~~ .. L. : ,, :,, ' ' ~ ., . ~j; . , ., .,::..! (.>. . . . . 1 ' 

Ruleg8~;~~rm1ts'R~Wiied, . >' ~ ' ', . . ,. >!,!~*L . '..i:vr-,,;: 

j . Rule @z;E?emrjtiong :$ :;: ;,, : :* :$$ 

:.*, :':,$: * , 1 I' .~~e~06~1~~~'?1.$p~~t~on~,~"': 1 ,&'$+.yge~ ;? ;%:$ 

, . R'ule 207:lt;~ed&l Malor Mod~f~cat~ons , .=.., .>$?.~?.:,,' .'&, ; , . :y ~L$$$A ':, ; 1 : Rule 214; Ern~s~on;Reduction $,redit:BanFng , .> I,': * .".) >. .~ ;,..<.' . 

Date Q&d, 20~ 

at El Centro, California. 

- ,.-I Rir~9~3~Mob~eSo~r~e,+~ission .Reduction Credit ?@$g . . :" , : ,? 

Riiepz, L&e confinid Ariiriial Faciiities:(LCAFs) qeyui+d% .'~ ' . - . ..* . , r. . . . . , ~. Rule 301, Peimit.Fees . - . . ..: >~ ,:. z,. .L..., . 

, , Rqlei307, LargeCopfined ~niinal ~a~ility ~e~~f?r~efly$yest~~k~

:.ya@Feey ; ' r , .; ". ,' -. >' ' , . .: , b. -. . , ,~ . .. . . , .; ,. . 

- - 461ea20, Beef ~Zblots 6rmerlyLivestbck Feed yards A 

, . : - ' ; . . 1 , :. .,, 

. . . . , . ,, . , 

t$e&e$i?$4g&&.$e!$:aSSf2~5,a'~$&Q-.9@$[ 10,,2006, ~&@pf .SU- 

~~~&~*~@~a~~~~s;"coun~A'dm~n~Strat~o &rite& 940 Main St., :El.Ge,ntro, 

&!(+&: *,.,&d2;, **$~ ,r,,>- ,... ...: ~. ,. . ~,<,.'.. , ,: . c. . . ,.. .,',~ ' '. ; ,>u, . ' .<. : . ._. . ..,.... , , .., *., & . , 

3, *',.;.*r-.&:.' -I--,.., : - :,,..., .:....: , :,, 

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%t~~$bl$&~-re%e!d atth,e'lm- ' 

&ia!cd"'~$.~ii Poli~tion.~ntroi p$r!~office,:~50~o:gfh$?.~~~~'" .* ent@,.CA.:,'. I .. 3. , ;,.. ,..' . . , i' : . .,,<., , ., -%, .:. ;, ..;.;,., .. i i;""' .. . . . ., .. 

1 ~he.pubjk.i$ invitidio'attend and'bi heaid; h he h$$ri?i, will ~~$,c$v$u&Ldjn 

1 i6.&rdanc.e i\iiih the.prqceduces.of the im~erjal Co~~~~50ard?~;~~p.eri.i

al&.%evc$'.~s, $he vst$,Board. ~f fourteen'q?,p!es.of wnnen.~opments .. 

arr?,r~e~ed,mo~e;~~an,~iveedays, bepre the hearing they:w~l/:~e.inc!uded$~.$~. , 

Board Membec? paFbti@rorthi:s item. ~~~m~ts,sh6~~d~e~add?~ss~iad i 

Poiriez, Air.Poliutio;ii ,cdnt@l Senior' ~naggr; oi Reyes ~omero;~peputy Air'. 

:Pollution . . Co"tr?i Officer, at 150 So. 9th St.; El Centro, CA 9~243:~': . . " . . 
October 10,2006 

IMPERIAL COUNTY AIR POLLUTION CONTROL DISTRICT 

STAFF REPORT 

Rule 201 - Permits Required; Rule 202 - Exemptions; Rule 206 - Processing of 

Applications; Rule 217 - Large Confined Animal Facilities (LCAFs) Permits Required; 

Rule 301 - Permit Fees; Rule 307 - Large Confined Animal Facility Fees formerly 

Livestock Feed Yard Fees; Rule 420 -Beef Feedlots formerly Livestock Feed yards. 

I BACKGROUND 

The Imperial County Air Pollution Control District (ICAPCD) maintains the 

responsibility of regulating air pollution from all sources within the County of Imperial. 

As required under state law, the JCAPCD adopts rules to achieve ambient air quality 

standards and enforces the provisions of local, state, and federal air quality laws. Clean 

air is essential to the well-being and welfare of each citizen of this country. The residents 

of the Imperial Valley, in turn, also have the inherent right to clean air. In order to be 

certain that our air is maintained at clean and healthy levels, the legislature has granted 

local air districts the autliority over the control of air pollution from all sources, with the 

exception of emissions produced by motor vehicles. 

Agricultural operations embody a significant source of air pollution throughout the state 

of California. Traditionally, agricultural operations had been exempted from any 

regulatory requirements. SB 700, within its contents, eliminated the exemption for 

agricultural operations in the fanning of crops or raising of fowl or animals from the 

permitting process of local air pollution control districts. Furthermore, the bill amended 

air pollution control requirements in the California Health & Safety Code to include 

requirements for agricultural sources of air pollution. This report presents the new and 

amended rules that the ICAPCD is required to adopt to be in accordance with the 

requirements of SB 700. Table 1 details the estimated emission reductions upon 

implementation of the ICAPCD's Proposed SB 700 rules. Based on this data, these rules 

sl~ould generate reductions of approximately 612 tons of VOC and 951 tons of PMlO per 

Table 1 : Summary of Reductions 

APPROVED OCT 10 2006 

Requirements (tonslday) 

Reductions from Proposed Control 

Requirements (tonslyear) 

Pollutant 

Uncontrolled Emissioiis (tonslday) 

Controlled Emissions (tonslday) 

Reductions from Prooosed Control 

PM10 Emissions 

8.7 

Dairy 

0.012 

0.006 

0.006 

VOC Emissions 

Beef 

Feedlot 

5.2 

2.6 

2.6 

Dairy 

0.10 

0.072 

0.024 

603.8 

Beef 

Feedlot 

5.43 

3.78 

1.65 

2.2 949 
II SENATE BILL 700: AGRICULTURE & AIR QUALITY 

On September 22, 2003, Governor Gray Davis signed into law Senate Bill 700 (SB700), 

authored by Senator Florez. The bill amended air pollution control requirements found 

within the California Health and Safety Code (CH&SC) to include requirements for 

agricultural ,sources of air pollution. Specifically, the bill requires Air Districts in 

California to remove exemptions previously granted to agricultural operations and 

practices. In review, SB 700 accomplished the following six main goals: 

a. The bill defmed "agricultural source" into state law - 

"...An agricultural source refers to a source of air pollution or a group of 

sources used in the production of crops, or the raising of fowl or animals 

located on contiguous property under common ownership or control ..." (SB 

700 Sec.2.a). The billspecifically list four categories of emissions sources that 

are part of the agricultural source: Confined Animal Facilities; internal 

combustion engines, including portable and off-road engines; sources subject 

to requirements under Title V; and sources of emissio~~s which are otherwise 

subject to district regulation under the Health & Safety Code or the federal 

Clean Air Act. 

b. The bill removed the restriction from state law that prevented air districts from 

requiring permits for agricultural sources - 

"It is therefore the intent of the Legislature to require the State Air Resources 

Boardand air quality management districts and air pollution control districts 

in the state to regulate stationary, mobile, and area sources of agricultural air 

pollution" (SB 700 Sec.l.7.b). 

c. The bill established specific permitting and exemption requirements for 

agricultural sources - 

The bill addresses general air permit requirements and exemptions for 

agricultural sources in five groups: sources subject to federal permitting 

requirements; permitting requirement for sources whose actual emissions 

equalor exceed 50% of the major source threshold; permitting exemptions for 

sources whose actual emissions are less than 50% of the major source 

threshold; sources that are de minimis; and sources that implement all listed 

mitigations. 

d. . The bill required emission control regulations in areas that did not attain the 

NationalAmbientAirQditJr Standarddfor_ PM10 - 

"By the earliest feasible date, but no later 

that is designated a moderate federal nonattainment area for an applicable 

ambient air quality standard for particulate matter as of January 1, 2004, shall 

adopt and implement control measures necessary to reduce emissions from 

agricultural practices ..." (SB 700 Sec.5.a). Imperial County was reclassified 

as a "serious" non-attainment area for PMlO on August 11, 2004, 

approximately seven months after the date of compliance set forth by SB700; 

therefore, Imperial County is required to comply with the requirements of a 

federal "moderate" nonattainment area instead of a federal "serious" 

nonattainment area. 

APPROVED OCT 10 2006 
e. The bill required permits and emission mitigation for the Large Confined 

Animal Facilities (LCAFs), as defined by ARB - 

"Not later than July 1, 2006, each district that is designated as a federal 

nonattainment area for ozone as of January 1, 2004, shall adopt, implement, 

and submit for inclusion in tlie state implementation plan, a rule or regulation 

that requires the owner or operator of a large confined animal facility to obtain 

a permit from the district to reduce, to the extent feasible, emissions of air 

contaminants from the facility" (SB 700 Sec.6.b). 

f. The bill required the California Air Pollution Control Officers Association 

(CAPCOA) to compile a clearinghouse of available emission controls and 

mitigation measures for agricultural activities - 

" ...[ CAPCOA], in consultation with the state board and other interested 

parties, shall, not later than January 1, 2005, develop a clearinghouse of 

available control measures and strategies for agricultural sources of air 

pollution and emissions from agricultural operations.. ." (SB 700 Sec.8). 

III STATUS OF AIR QUAJJTY IN IMPERIAL COUNTY 

Imperial County is currently classified at tlle state level as a "moderate" non-attainment 

area for the 1-hour ozone standard and non-attainment for PM10. By federal standards, 

Imperial County is currently classified as "marginal" non-attainment for the 8 hour ozone 

standard, and it was reclassified as "serious" non-attainment for PMlO on August 11, 

2004. As presented in Table 2, the federal eight-hour ozone and PMlO standards have 

been exceeded in the Imperial County during the past six years. Due to the 

reclassification as a "serious" non-attainment area, the ICAPCD will soon be required to 

develop a PMlO Atlainment Plan. In addition, Imperial County is required to 

demonstrate attainment with the 8-hour ozone federal standard by 2007. These facts 

make the impact of agricultural sources a critical consideration in the implementation of 

SB 700 requirements. 

Table 2, Number of Days over the Federal 8-hour Ozone and PMlO Standards. 

Table 3 is a summary of the 2004 Volatile Organic Compounds (VOCs) and PMlO 

inventory for Imperial County. The emission estimates ase based on published CARB 

data. The Farming Operations source category includes emissions from farming and 

Large Confined Animal Facility operations. SB 700 mandates reductions of VOC and 

PM10 emissions from agricultural operations which includes both farming operations 

- 2005 -- 

2004 

2003 

2002 

2001 

2000 

APPROVED OCT 10 2006 

3 

Calculated Number of 

Days over the Federal 

Year Number of Days over the 

Federal Eight-hour Ozone 

~tkdard 

- - -- 10 - - 

1 

8 

13 

18 

5 

PMlO Standard 

- 12~ ~ ~-~~~~ -

'1 4 

25 

18 

18 

38 
(tillingharvesting), and large confined animal facilities (beef feedlots, dairy cattle, etc). 

After mitigation, tlie faming operations source category represents 15.35% of VOC 

emissions and 4.26% of PMlO emissions from the total emission inventory for Imperial 

County. 

Tilling and Harvesting 

Beef Feedlots 

IV PROPOSED AMENDMENTS AND NEW RULES: 

I yards 

Rule 806 1 Conservation Management Practices I Adopted New Rule 

4 APPROVED OCT 10 2006 

Status 

Proposed Amendment 

Proposed Amendment 

Proposed Amendment 

Proposed New Rule 

Proposed Amendment 

Proposed Amendment 

Proposed Amendment 

Rule Number 

Rule 20 1 

Rule 202 

Rule 206 

Rule 21 7 

Rule 30 1 

Rule 307 

Rule 420 

Rule Name 

Permits Required 

Exemptions 

Processing of Applications 

Large Confiiled Animal Facilities (LCAFs) 

Large Confined Animal Facility Fees 

Large Collfined Animal Facility Fees 

Beef Feedlots formerly Livestock Feed 
These rules are proposed to be amended in order to facilitate the permitting of equipment 

at agricultural facilities, including confined animal facilities, by streamlining 

requirements, incorporating fee provisions, and identifying equipment that is exempt 

from written permits. 

SB700 requires for PM10 non-attainment areas to adopt and implement control measures 

necessary to reduce emissions fiom agricultural practices, including: tilling, discing, and 

cultivation. On November 8, 2005, the Air District Board adopted a series of rules under 

Regulation VIII, Fugitive Dust Rules, in order to reduce the amount of fine Particulate 

Matter (PM-10) entrained in the ambient air as a result of emissions fiom anthropogenic 

Fugitive Dust (PM-10) sources. These series of rules outline the actions necessary to 

prevent, reduce, and mitigate PM-10 emissions. Rule 806, Conservation Management 

Practices, was part of this package and is currently being enforced. Rule 806 applies to 

all agricultural operation sites of forty (40) or more acres in size and requires the usage of 

Best Available Control Measures (BACM) to mitigate fugitive dust from land preparation 

and cultivation, harvesting, unpaved roads, and unpaved traffic areas. The ICMCD 

believes Rule 806 meets the requirements of SB700, and as such, no further amendments 

are deemed necessary to the rule at this time. 

Because these rules incorporate amendments to existing rules, with the exception new 

proposed Rule 217, the impacts on the public and industry due to the rulemaking process 

will be minimal. A review of the regulations, under the jurisdiction of the ICAPCD, 

resulted in the identification of six rules which required necessary amendments, along 

with the new proposed rule (Rule 217, Large Con£ined Animal Facilities) as per SB 700. 

Following is a brief description for each rule that has been identified as requiring an 

amendment and its potential impact: 

1. Amended Rule 201 -Permits Required ~~ ~ ~ ~ ~ ~ 

This rule amendment incorporated editorial language. The words "Feedlot certificates" is 

being replaced by "Large Confined Animal Facilities." The change will correlate the 

requirement of a permit to the newly proposed Rule 217 - Large Confined Animal 

Facilities. Language was added identifying Rule 217 as a source rule. There will be a 

less than significantimpact-bytheeeamendmentstotbisde hy_possiL!e_~impact~~~~~~~b~e 

limited to Dairy and Cattlemen as they directly relate to Rule 217 and will be interpreting 

the changes. In addition, no costs are associated with this amendment. This is an 

administrative rule with no direct impact on emission reductions. 

2. Amended Rule 202 -Exemptions 

This rule amendment directly affects "Agricultural Sources," as it identifies a source 

group exempt from the permit requirements. Under subsection E.10 "Agricultural 

Operations" has been replaced by "Agricultural Sources." The exemption includes 

stationary combustion agricultural sources with less than a combined actual emissions of 

one half the applicable threshold for a major source. This amendment also identifies 

APPROVED OCT 10 2006 

5 
CAFs, which are not considered large, to be exempt. The ICAPCD has not identified any 

agricultural source that may be affected by this exemption; therefore, there is a less than 

significant impact by the amendments to this rule. There are no costs associated with this 

amendment. 

3. Amended Rule 206 -Processing of Applications 

The amendments in Rule 206 were made to incorporate editorial language. The words 

"Livestock Feed Yard certificates" have been removed fiom section B, Ministerial 

permits. Large Confmed Animal Facilities are not considered ministerial as defined by 

ARB. There is a Jess than significant impact by the amendments to this rule. Any 

possible impacts are by Dairy and Cattlemen as they directly relate to Rule 217. There 

are no costs associated with this amendment. 

4. Amended Rule 301 -Permit Pees 

This rule amendment for Rule 301 incorporated editorial language. The words "feedyard 

certificates" are being replaced by "Large Confined Animal Facility Permits" under the 

section for "Review Fees." Similarly, the words "or a Feed Yard Certificate" has been 

deleted for clarity under the section "Annual Renewal Fee." There is a less than 

significant impact by the amendments to this rule. Again, any possible impacts are by 

Dairy and Cattlemen as they directly relate to Rule 217. There are no costs associated 

with this amendment. 

5. Rule 307 - Large Confined Animal Facility Fees formerly Livestock Feed 

Yard Fees 

This rule revision amendment incorporated editorial language to the body of the rule and 

the title. The words "livestock fee yard" and the sentence "Beginning & the year 2005, 

the annual certificate fee shall increase at the rate of fourteen percent (14%)" has been 

deleted for clarity. The words "certificate" has been replaced by "permit." Similarly, the 

fee rate for year 2005 has been tagged for deletion for clarity. Currently there are 38 beef 

feedlots and 3 dairy facilities operating in Imperial County. All beef feedlot facilities are 

currently paying certificate fees under this rule, and they will continue paying the same 

fees under a Permit to Operate.-~Therefore,dheimpact_fromamenimdment~6lo thisless tban significant. The three dairy operations will now be required to pay Pe 

Operate fees under this rule. However, this is a minimum fee that is only intended to 

recuperate the cost of operation of the program. There is a less than significant impact by 

the amendments to this rule. 

6. Rule 420 -Beef Feedlots formerly Livestock Peed Yards 

This rule incorporated several editorial changes to the body of the rule as well as the title. 

The changes were in direct correlation to the newly proposed Rule 217, Large Confined 

Animal Facilities. No substantial requirements were changed or altered except to add or 

change language for better clarification. This rule was adopted November 19, 1985 and 

APPROVED OCT 10 2006 
has been in force for 21 years. This rule regulates PMlO emissions from cattle feed 

yards. This rule does not affect Dairy operations. The principal changes included 

language to remove the "certificate" aspect of the rule. With the new alteration, 

certificates become Permits to Operate or Auihorities to Construct. In addition, a 

definition of "Random Sampling" was included to help identify the manner of sampling. 

Similarly, the word "averaged" was included for the recorded readings for clarification of 

sampling. Since this rule was adopted long ago and is currently being enforced, the 

impact of this rule revision on existing sources is less than significant. CAPCOA and 

ARB used this rule as a model for the development of mitigation measures for Livestock 

Feed Yards. 

Currently there are 38 beef feedlots and 3 dairies under ICAPCD's jurisdiction. The Air 

Resources Board has recently developed new PMlO emission factors for dairy and beef 

feedlot operations. In a letter to the Air Resource Board on February 28, 2006, the 

ICAPCD requested to update the emission inventory for these source categories to reflect 

the new emission factors and control efficiency for applicability, or Rule 420 on beef 

feedlots. A 50% PMlO efficiency control is assumed for beef feedlots due to the 

implementation of fhe mitigation measures required by Rule 420. The PMlO emissions 

fiom dairy cattle category has been adjusted with a 50% control to reflect the PMlO 

control measures required by Rule 217. Based on the 2004 cattle population for dairy 

and beef feedlots, it is estimated that a reduction of 2.2 and 949 tons per year, 

respectively, will take place due to the application of the new control measures required 

by Rules 420 and 217. Table 4 illustirates the updated emission inventory as follows: 

Table 4 Cattle-Related PMlO Emission Reductions 

Source Category 

2004 Cattle Population 

Uncontrolled Emission Factor 

(lbs PM1011000 headlday) 

Controlled Emission Factor 

(tonslday) 

Dairy Cattle 

3,615 

6.72 

Uncontrolled PMlO Emissions 0.012 5.2 

3.36 

Controlled PM10 Emissions - - (tons/day) ~ ~~~ ~~~ ~- -~ ~ 

SB 700 stipulates that local air pollution control and air management districts shall, not 

later than July 1, 2006, adopt, implement, and submit for inclusion in the state 

implementation plan, a rule or regulation that requires the owner or operator of a LCAF, 

as defined by CARB, to obtain a pewit &om the district to reduce, to the extent feasible, 

Beef Feedlot 

360,468 

28.90 

14.45 

~ ~- ~ - ~~~ ~ 

(tonslday) 

PMlO Reductions 

(tonslyear) 

- APPROVED OCT 10 2006 

0.006 2.6 

PMlO Reductions 

7. Proposed Rule 217 - Large Confined Animal Facilities (LCAF) 

2.2 949 

0.006 2.6 
emissions of air contaminants from the facility. The ICAPCD has developed Proposed 

Rule 217 to satisfy SB 700 and California Health & Safety Code Section 40724.6 

requirements. 

SB 700 appointed CARB to create a defstion for the source category of a LCAF by July 

1, 2005. Included in the process of developing the proposed defstion, CARB was 

required to review all available scientific information, including, but not limited to, 

emission factors for CAFs and the effect of these facilities on air quality in the State's 

various air basins. In addition, CARB was directed to consider the impact of emissions 

from CAFs on attainment and maintenance of ambient air quality standards. 

In developing the proposed definition for LCAFs, CARB staff considered the following 

key factors: 

1. Severity and nature of the air quality problem in various local air districts. 

2. Number of animals and their associated emissions per district. 

3. Status of research on emission factors. 

4. Efficiency in definition structure (number of animals relative to facility number): 

5. Ability of local air districts to expand the def~tion ifwarranted. 

After considering the above factors, CARB staff has adopted the thresholds shown in 

Table 5: 

Table 5 - LCAF 

~~ ~ ~ ~~ 

I lamas,' Others 1 30,000 / 60,000 

Source. -- ~ ..... California Air - ~~~~~~~ Resources Board Staff Re~ort: "Initial Statement of Reasons for Rulemaking Public 

Hearing to Consider the Large Confined ~nimal'Facility Definition", May 6,2005, modified ~e~tember 7, 

2005. 

The aim of defining the term, LCAF, is to address the combined, aggregate air quality 

impacts of the livestock industry in California. According to the CARB Staff Report, 

"Initial Statement of Reasons for Rulemaking Public Hearing to Consider the Large 

Confined Animal Facility Definition," CARB staff did not take an individual facility 

emissions approach in defining a LCAF because it is impractical and uncertain, in part 

8 APPROVED OCT 10 2006 
due to the developing state of livestock emissions estimation research. At this time, 

facility emissions are calculated on a per animal basis, pending completion and peer 

review of research on specific emission rates for various processes at a facility. 

Imperial County carries the current classification of being an ozone non-attainment area. 

As a result, for dairies, the definition of a LCAF is 1,000 milking cows as defined in SB 

700, and for beef feedlots the definition of a LCAE is 3,500 heads. An estimated three 

dairies operate in the area under the ICAPCD's jurisdiction of 1,000 or more milking 

cows, while approximately 38 beef feedlots with a capacity to feed more than 3,500 

heads operate within the Imperial County. The Imperial County does not currently house 

any poultry farms or egg ranches. 

Proposed Rule 217 was developed to satisfy the requirement that all LCAFs have permits 

that seek to minimize their emissions. In accordance with SB 700 and California Health 

& Safety Code Section 40724, Proposed Rule 217 requires that the owner or operator of 

LCAEs submit an application for an Authority to Construct (ATC)/Permit to Operate 

(PTO) thal includes: 

1. The information that the Air Pollution Control Officer, or his designee, 

determines is necessary to prepare an emissions inventory of all regulated air 

pollutants emitted from the operation, inchding, but not limited to, the provisions 

listed hereafter. 

2. List of a11 stationary combustion equipment. 

3. List of all other significant sources of air pollution, including, but not limited to, 

stationary irrigation pumps, gasoline storage tanks, etc. 

4. Total capacity of the facility in terms of commercial production animal and bird 

population. 

5. An emissions mitigation plan that demonstrates that the facility will use 

Reasonably Available Control Measures (RACT) to reduce emissions of 

pollutants that contribute to the non-attainment of any ambient air quality 

- standard,-andthataredar~thinhinflleAirDiskici~s ~eguhb 

6. In addition, ihe dust control plan for beef feedlots shall adhere to the requirements 

within Rule 420. 

Proposed Rule 217 requires that all LCAFs apply for and obtain an ATCRTO that 

includes a mitigation plan that the LCAF will implement to reduce its emissions. The 

owner or operator of a LCAF slmll submit an annual compliance plan which updates the 

information listed above. Any permit that is issued to a LCAF will be subject to all 

pertinent provisions of the California Health & Safety Code and the Air District Rules 

and Regulations. The Air District believes that the above requirements in Proposed Rule 

217, including the emissions mitigation plan, will significantly reduce emissions from 

9 APPROVED OCT 10 2006 
LCAFs. Table 6 below lists the number of mitigation measures and total number of 

options in Proposed Rule 217, for both major types of facilities. Since no swine, poultry 

or egg ranches exist within the Imperial County, the ICAPCD is not currently proposing 

mitigation measures for these source categories. 

Table 6 -Number of Mitigation Measures and Total Number of 

Options for ~eef~eedlot andDairy Facilities. 

I I ReefFeedlot I Dairv 

Exis re previously certificated through Rule 420 as livestock 

feed yards, will be required to reapply for an ATCIPTO in order to be reclassified as 

LCAFs, so long as they meet the appropriate standards. In the interim however, current 

Livestock Feed Yard certificates and conditions shall continue to be honored. Prior to the 

approval of any new or modified LCAF permit, the ICAPCD shall provide public notice 

for duration of 30 days and comment on any draft permit. Upon the close of the public 

review period, the ICAPCD may alter the conditions of the permit based on the 

comments it receives during the time frame. If the modifications are sound and 

warranted, the ICAPCO will proceed with approval. 

-- 

Feed and Silage 

Milk Parlor 

Freestall Barns 

Housing 

Solid Manure 

Liquid Manure 

Land Application 

TOTAL 

SB 700 Section 40724.6(d)(l)(B) requires moderate and serious ozone non-attainment 

areas to implement Reasonably Available Control Technology @ACT), while severe and 

extreme non-attainment areas are required to implement Best Available Retrofit Control 

Technology (BARCT). Imperial County has the current classification of a "marginal" 

ozone non-attainment area which is the lowest level of non-attainment, lying one step 

below the moderate non-attainment classification. SB 700 does not require any specific 

control technology for "marginal" non-attainment areas. However, in the interest of 

-pre emP~fre-stmCcellt~Wadddfuturee degradation of tl,e-air -qualityof 

County, the ICAPCD has opted to recommend the implementation of RACT. RACT is 

defined as an emission limitation that is based on the maximum degree of reduction 

achievable, taking into account environmental, energy, and economic impacts by each 

class or category of source. Proposed Rule 217 requires compliance with RACT and 

provides a menu of mitigation measures for beef feedlots and dairies. The ICAPCD is 

confident that the dust and emission mitigation requirements in Regulation VIII - 

Fugitive Dust Rules, will satisfy the RACT requirements for dairy operations. Therefore, 

operators of dairies that are in compliance with the above set of rules are not required to 

take any further action for Proposed Rule 420 RACT compliance. 

APPROVED OCT 10 2006 

10 

- -- . . 

3of9 

OofO 

OofO 

4of 10 

1of5 

0 of 0 

2of6 

10 of 30 

3of 10 

1 of2 

2of9 

4 of 9 

1 of5 

1 of5 

2of6 

14 of 46 
Volatile Organic Compounds (VOCs) are the principal category of pollutants emitted 

from Confined Animal Facilities (CAFs). Research is continuously being carried-out in 

order to determine and analyze emission factors of VOCs from livestock operations, 

especially in regards to dairies and beef feedlots operations. San Joaquin Valley Unified 

Air Pollution Control District (SJVUAPCD) has developed its own VOC emission 

factors for dairy and beef feedlot operations. The VOC emission factors &om 

SJWAPCD, 11 lbshiead-year for beef feedlots and 19.3 lbhead-year for dairies, were 

also used to evaluate VOC emissions for the Imperial County. The ICAPCD has 

estimated VOC reductions of 25% and 30.6 for dairies and beef feedlots, respectively, 

due to the application and enforcement of the control measures proposed in Rule 217. 

Details of the calculation of VOC reductions from Rule 217 can be found in Appendix A. 

As previously stated, 38 beef feedlots and 3 dairies operate within the jurisdiction of the 

ICAPCD, with a total 2004 cattle population of 364,083 heads. This figure, along with 

San Joaquin's emission factors and control efficiency, formed the basis for estimating 

total VOC reductions in Imperial County due to the implementation of the various 

mitigation measures found within Rule 217. Based on this information, it is estimated 

that a VOC reduction from dairies will be 8.71 tons per year, whereas beef feedlots will 

see a reduction of 603.8 tons per year. Details of the calculation of VOC reductions fiom 

Rule 217 can be found in Appendix A. Table 7 below presents the cattle-related VOC 

emission reductions: 

1 Uncontrolled Emission Factor 1 19.3 1 11.0 I 

Table 7 Cattle-Related VOC Emission Reductions 

Source Category 

(lbs VOCheadIyear) 

Dairy Cattle 

I 

(tonlday) 

Beef Feedlot 

1 

2004 Cattle Population 

5.43 

Control Efficiency of Mitigation I 25% 

Measures 

VOC Reductions 

30.5% 

(lbs VOClbeadiday) 

(tonsly ear) 

3,615 

Controlled Emission Factor 7.65 

V PUBLIC PARTICIPATION 

360,468 

14.48 

Controlled VOC Emissions 3.78 

The District conducted two public workshops and presented this staff report and its 

conclusions to any interested parties on June 15, and August 17, 2006. The general 

public was given an opportunity to comment on the findings of the staff report. The 

0.072 

APPROVED OCT 10 2006 

11 
notices were conducted according to policy thus advertisements were placed June 11, and 

August 13,2006 in the Imperial Valley Press announcing the workshops. 

VI RECOMMENDATIONS: 

APCD ADVISORY BOARD: 

The Air Pollution Control District Advisory Board met to discuss tlie new and revised 

rules on September 13,2006. The representatives present were in support of adoption of 

proposed new and revised rules. 

STAFF: 

The Imperial County Air Pollution Control District staff recommends adoption of the 

new and revised rules along with the accompanying staff report and its findings. It is a 

fulfillment of the legislative obligation imposed upon the Air District by SB 700 

W DECLARATION OF FINDINGS: 

The Imperial County Air Pollution Control District Board hereby finds as follows: 

The adoption of the staff report and it's findings are exempt fiom the requirements of 

Public Resources Code Section 21000 et seq. under California Environmental Quality 

Act (CEQA) guidelines, in the California Code of Regulations Section 15061 @)(3). 

The ICAPCD is a regulatory agency and the public agency with the principle 

responsibility for carrying projects related to Air Pollution and the control thereof. 

Clean air is a valuable and essential natural resource. 

The stareport and its findings described herein will not significantly affect air quality or 

emissions limitations and therefore is exempt fkom Health and Safety Code (HSC) 

Section 40728.5, which requires a socioeconomic analysis of the proposed action to be 

performed. 

~ ~ ThherIe ~llai3een no-vidence prescntea t6~~suugggeest ~&zt-.&e ~implem~entationof &estaff 

report and its fmdings will lead to or result in cumulative adverse impacts. 

Health and Safety Code Sections 40701.5 and 40702 provide the authority to the 

ICAPCD to enact this staff report and its findings. 

The findings within ihe staff report are clear and capable of being understood by those 

persons directly affected by it. 

The staff report and its findings do not conflict with or contradict any existing statute, 

court decision, or state or federal regulation. 

APPROVED OCT 10 2006 
The findings of tlie staff report are not duplicative of any existing state or federal 

regulation. 

The Imperial County has a population of less than 500,000 people. 

APPROVED OCT 10 2006 
CUSTOM CA7TLE FEEDING BIG BALES 

Office (760) 344-3430 Fax (760) 344-8523 Feedlot (760) 348-2295 

299 WEST MAIN STREET P. 0. BOX 118 BRAWLEY, CALIFORNIA 92227 

September 7,2006 

Mr. Victor Camllo, Chairman 

Imperial County Board of Supervisors 

940 West Main Street 

El Centro, C.4 92243 , . 

Re: Support for Revisions to Rules 101,201,202,206,301,420 and Proposed Rule 

217Rules Affecting Air Quality for Feed Yards 

Dear Chairman Carrillo, 

To begin, we would like to thank the Imperial County Air Pollution Control District 

(APCD) staff for their work on updating existing rules and proposing new rules in order 

to implement SB700, which provides for decreasing air quality emissions for Confined 

Animal Feeding Operations (CAFO). The process of having a Technical Advisory 

Committee (TAC) that represented the industry in the rules formation proved to be 

beneficiai as the draft rule provided at the workshop is workable for the industry and able 

to decrease emissions for your community. 

Currently our operation is doing many thngs to decrease the amount of emissions iiom 

our feedyard. We have installed a new sprinkler system throughout the entire yard to 

help in settling the dust. We also run two water trucks seven days a week spraying down 

the roadways as well as the cattle pens around the feedyard in an effort to decrease the 

dust. Furthermore, cattle pens at the feedyard are cleaned regularly and the manure is 

hauled out to our composting operation. This decreases the manure build up at the back 

of each pen. Brandt Company and its related companies have been committed to the 

interests of the Imperial Valley communities since our inception in 1945. We are 

currently provide full time employment to 85 people with an average monthly payroll in 

excess of $200,000. 

To conclude, we urge you to support the rules as proposed at the August 17,2006 

workshop. Althbugh some of the measure will be costly andwill change the way that we 

currently do business we believe that these rules will work for our operation and for o& 

community. Thank you for your time and attention to our comments. . . . 

352 E.Shank Road 

Brawley, CA 92227 Office 760.344.0641 

September 12,2006 

Mr. Victor Camllo, Chairman 

Imperial County Board of Supervisors 

940 West Main Street 

El Centro, CA 92243 

Re: Support for Revisions to rules 101,201,202,206,301,420 and Proposed Rule 217/Rules 

Affecting Air Quality for Feed Yards 

Dear Chainnan CarriIlo: 

I would like to thank the Imperial County Air Pollution Control District (APCD) staff for their 

work on updating existing mles and proposing new mles in order to implement SB700, which 

provides for decreasing air quality emissions for Confmed Animal Feeding Operations (CAFO). 

The process of having a Technical Advisory Committee (TAC) that represented the industry in 

the rules formation proved to be beneficial as the draft rule provided at the workshop is workable 

for the indusry and able to decrease emissions for our community. 

Currently ButterSpur Cattle Feeders owns and operates two feed yards on Shank Road northeast 

of Brawley. Each feed yard has a 4500-gallon water truck that pumps approximated 180 gallons 

per minute. The amount that can be applied to feed yard area daily is approximately 76,500 

gallons or 17 loads. Schedule for spraying is approximately 3 a.m. to 8 p.m. The water truck 

driver sprays water directly in pens, on alleys and work areas, as well as dirt road ways and feed 

alleys. Prior to any sorting or intentional moving of cattle, the driver will water in that area to 

reduce the amount of dust generation. In addition, we operate sprinklers in our alleys and pens. If 

canals are out, we fill our trucks from another location until water is restored, and attempt if 

possible to reduce the amount of pen changes or sorting of cattle until canals are recharged. We 

also fax in a copy of our '?\Totice of Canal Out" to the Imperial County Air Pollution Control 

District. Our plan for manure removal is to clean pens every 6 to 12 months annually. 

. . 

ButterSpur emplpys 15 to 20 people throughout theyear. W; actively suppoi the community by 

providi~lg facilitiesfor Josa! 4-Hcrs td rahe !ivestcck as :.i!I as Spr?ssc;ing 1,c:sI youth sooce1 . . teams. , . 

To conclude, I urge you to support the rules as proposed at the August 17,2006 worksl~op. 

Although some of the measure will be costly and will change the way we currently operate, I 

believe that these rrrles will work for my operation and for our community. Thank you for your 

time and attention to my comments. ~. ~ 

, . 

, 

Steve Snow . . . . .. , 

General Manager. . , . . . . . , . .. , 

EDW. "Jiggs" JOHNSON BOB O'DELL 

El Toro Land & Cattle Inc. 

CUSTOM CATTLE FEEDING 

P. 0. Box G Heber, CA 92249-0280 . Phone 760-352-6312 . Fax 760-352-1063 

September 06,2006 

Mr. Victor Carrillo, Chainnan 

Imperial County Board of Supervisors 

940 West Main Street 

El Centro, CA 92243 

Re: Support for Revisions to Rules 101,201,202,206,301, 420 and 

Proposed Rule 217/Rules Affecting Air Quality for Feed Yards 

Dear Chairman Canillo, 

To begin, I would like to thank the Imperial County Air Pollution Control 

District (APCD) staff for their work on updating existing rules and 

proposing new rules in order to unple~nent SB700, wlGc11 provides for 

decreasing air quality emissions for Confined Animal Feeding Operations 

(CAFO). The process of having a Technical Advisory Committee (TAC) 

that represented the industry in the rules formation proved to be beneficial as 

the draft rule provided at the worlcshop is workable for the industry and able 

to decrease emissions for your comnunity. 

Currently El Toro Land & Cattle Company, Inc. has been doing a number of 

procedures to decrease einissions into the almosphere, and they are as 

follows: 

~~ ~~ ~ ~ ~ ~~~ ~ 

~~~~-~ ~~ -~ ~ ~~- ~~~ ~~~ ~ ~ ~ ~ p~ . 

1. El Toro Land & Cattle feed high nzoisture steam flaked c0r.n. 

2. Dust is well contained at the mill because 71zost evelything is an 

enclosed systenz. 

3. Feed troughs are fed so that cattle clean up feed daily 

4. In the event of rain, feed troughs a7.e cleaned before the next feed is 

delivered, and before any feed spoils. 
EDW. "Jiggs" JOHNSON BOB O'DELL 

El Toro Land & Cattle Inc. 

CUSTOM CATTLE FEEDING 

P. 0. Box G Heber, CA 92249-0280 Phone 760-352-6312 Fax 760-352-1063 

5. All water troughs have floats contained in cages to prevent overflow 

of troughs. 

6. Manurse is scraped and removed9onz colrals as needed. Manure 

depth never exceeds I8 inches. - 

7. Any d7y corrals are sprinkled with our water wagons to maintain a 

moisture level between 20% and 40% in the top 3 inches of nzanure 

buildup. 

8. Manure removedfo7-m the cor7-als is transported to a ya~d where it is 

processed by Bull Enter.prises. 

9. Roadways and access areas have been gvaveled to prevent '?rack-on " 

to county roads. 

10.In the event of a rain storm no runoff occu~~s because we are 

surrounded by be7.m~ and have a large drainage lagoon that we pump 

all sto~*m water into. 

I1. El Toro Land & Cattle has expenditures in the local economy in the 

anzount of $3,386,780per year as listed below: 

a. El Toro Land & Cattle spends $300,780 per year, for dust 

control, between the Heber cattle yard and Mc Cabe cattle 

yard. 

b. El Toro Land & Cattle has38 employees that live in the 

conzmunity, with an annual Payroll of $ I, 840,000per year. 

The co7npanypays for Health Insurance as an added benefit for 

each employee in the anzount of $228,00Oper year. 

c. El Toro Land & Cattle patronizes local conzpanies and vendors 

for Supplies, Repairs, and Sewices in the amount of $973,000 

per year. 

d. Tlze feed yard contributes $45,000 dollars per year in 

donatiomdo- the-communiQL _Also,,,corzl.ibutions of Deep_Pit 

BBQ, and all the,fiJcings for seve~al schools and organizations - 

through out the valley for there fundr.aisers. 
EDW. "Jlggfi" JOHNSON BOB O'DELL 

El Toro Land & Cattle Inc. 

CUSTOM CATTLE FEEDING 

P. 0. Box G Heber, CA 92249-0280 . Phone 760-352-6312 ' Fax 760-352-1063 

To conclude, I urge you to support the rules as proposed at the August 17, 

2006 workshop. Although some of the measure will be costly and will 

change the way that I currently do business I believe that these rules will 

work for my operation and for ow: community. Thank you for your time and 

attention to my comments. 

Sincerelv. 

Vice President 
PO Box G, Heber CA 92249 

(760) 352 - 6312 

(760) 352 - 1063 FAX 

El Tor0 Land & Cattle Feed yard Dust Control Plan 

Name Of Facllffy: El Toro Land & Cattle Co., Inc. Heber Yard 

Iotation: 96 E. Fawcett Rd, Heber CA 92249 

Size of Facility: 

Gross Acres of Facility 131 Acres, 

Approximately 60 Acres is covered with corrals 

26 Acres in open fields 

45 Acres are used for Storage or Roads 

Method 01 Dust Control: 

Two (2) water trucks will be used for dust control 

o Size of water truck tank capacity in Gallons and delivery 

pump capacity (gal I min). 

Delivery Pump 

Capacity * 

1,000 gallmin 

1,000 gallmin 

o Amount of water (gallons) that can be applied daily to feed 

yard area. 

Size Amount per 10 Hrs 

Water Truck 6,000 

Water Truck 4,500 

300,000 gal I 10 hrs 

225,000 gal I10 hrs 
Ell T@u@ Lamd 8 Gattoo @@n, UWG, 

PO Box G, Heber CA 92249 

(760) 352 - 6312 

(760) 352 - 1063 FAX 

El Toro land & Cattle Feed yard Dust Control Plan 

Name Oi FaciliR El Toro Land & Cattle Co., Inc. Heber Yard 

Location: 96 E. Fawcett Rd, Heber CA 92249 

o Schedule for spraying will be on an as needed basis to 

control dust, and to maintain appropriate health and well 

being of livestock 

Water truck tanks capacities are of sufficient size to minimize 

water tank refilling 

Water truck pump capacity is large enough to cover % the span of 

the pen form alley-way to alley-way. 

Water spray from truck pump boom is applied uniformly across 

the pen from each alley-way during each truck pass. 
PO Box G, Heber CA 92249 

(760) 352 - 6312 

(760) 352 - 1063 FAX 

El Toro land & tattle Feed yard ~ost Control plan 

Name of FacIllty: EI Toro Land & Cattle Co., Inc. 

La Brucherie Ranch McCabe Yard 

LOC~~~OIR: 1407 La Brucherie Road, CA 

She of Facility: 

Gross Acres of Facility 48 Acres, 

Approximately 36 Acres is covered with corrals 

12 Acres are used for Storage or Roads 

Method of ~1st control: 

Two (2) water trucks will be used for dust control 

o Size of water truck tank capacity in Gallons and delivery 

pump capacity (gal I min). 

Delivery Pump 

SizeIGallons Capacity 

o Amount of water (gallons) that can be applied daily to feed 

yard area. 

Size Amount per 10 Hrs 

~ ~ - ~~~ ~ ----- ~ 

Water Truck 5,000 250,000 gal I10 hrs 

Water Truck 3,500 175,000 gal 110 hrs 
PO Box G, Heber CA 92249 

(760) 352 - 6312 

(760) 352 - 1063 FAX 

El Toro land & Cattle Feed yard Dust Control Plan 

Name 01 Faellily: El Toro Land & Cattle Co., Inc. 

La Brucherie Ranch McCabe Yard 

Lo~a~on: 1407 La Brucherie Road, CA 

o Schedule for spraying will be on an as needed basis to 

control dust, and to maintain appropriate health and well 

being of livestock. 

Water truck tanks capacities are of sufficient size to minimize 

water tank refilling 

Water truck pump capacity is large enough to cover '/z the span of 

the pen from alley-way to alley-way. 

Water spray from truck pump boom is applied uniformly across 

the pen from each alley-way during each truck pass. 








907 Brockman Rd El Centro, CA 92243 

Phone 760-352-4531 Fax 760-357-5479 

September 18,2006 

Mr. Victor Carrillo, Chairman 

Imperial County Board of Supervisors 

940 West Main Street 

El Centro. CA 92243 

Re: Support for Revisions to Rules 101,201,202,206,301,420 and Proposed Rule 

2171Rules Affecting Air Quality for Feed Yards 

Dear Chairman Carrillo, 

The Imperial County Air Pollution Control District (APCD) and their staff has been a leader in 

dust control in California. The first feedlot dust ordinance in California with measurable control 

methods was established by Imperial County APCD. Whereas some counties and districts are 

playing catch-up we have had a long history of the county working with feedlots to control dust. 

This experience gives Imperial County APCD the background for updating existing rules and 

proposing new rules in order to implement SB700, which provides for decreasing air quality 

emissions for Confined Animal Feeding Operations (CAFO). The process of having a Technical 

Advisory Committee (TAC) that represented the industry in the rules formation proved to be 

beneficial as the draft rule provided at the workshop is workable for the industry and able to 

decrease emissions for our community. 

Meloland Cattle Company currently feeds 16,000 head and employees 17 full time employees 

at two caffle feeding facilities. We have 12,000 head in our main yard at 907 Brockman Road, 

El Centro and use a water truck to spray the pens and roads. We usually keep about 4,000 

head at our Brandenberg feedlot at 903 West Hwy 98. There we use a combination of 

sprinklers and a water wagon to water the pens and roads. We try to maintain moisture in our 

pens that is adequate to control dust at all times and during dry times of the year we dedicate 

1% -2 full time employees to dust control besides the cost of running pumps and trucks. 

The rules as proposed at the August 17,2006 workshop are a good compromise that will meet 

the requirements of SB700. Although some of the measures will increase compliance costs and 

will change the way that I currently do business I believe that these rules will work for my 

operation and for our community. Thank you for your time and attention to my comments. 

Bill Brandenberg, 

Manager 
-- 

P. 0. Box 1025 a Brawley, CA 92227 a (760) 344-4718 Office (760) 344-9770 Fax 

September 7,2006 

Mr. Victor Carrillo, Chainnan 

Imperial County Board of Supervisors 

940 West Main Street 

El Centro, CA 92243 

Re: Support for Revisions to Rules 101,201,202,206,301,420 and Proposed Rule 

217/Rules Affecting Air Quality for Feed Yards 

Dear Chairman Canillo, 

To begin, I would like to thank the Imperial County Air Pollution Control District 

(APCD) staff for their work on updating existing rules and proposing new rules in order 

to irnplenlent SB700, which provides for decreasing air quality emissions for Confined 

Animal Feeding Operations (CAFO). The process of having a Technical Advisory 

Committee (TAC) that represented the industry in the rules formation proved to be 

beneficial as the draft rule provided at the workshop is workable for the industry and able 

to decrease emissions for your co~nmunity. 

All of the feedlot operators here in the Imperial County strive to be good neighbors, 

protect our environment, and be good stewards of our operations and our animals. 

Mesquite Cattle Feeders, Inc. expends considerable time and money to insure that dust 

and manure emission impacts are minimized. Our feedlot is equipped with a sprinkler 

system, which is utilized 2 to 3 tunes per day at 2-how intervals over a 24-how period 

during dry weather. We also run a water tmck for 18 hours a day to keep alleys and 

driveways watered. At considerable capital expense we have purchased side dump trucks, 

a loader; and a bulldozer to clean manure froin ow pens in a timely manner, and 

minimize the impacts of PM 10, and VOC emissions in the county. 

To conclude, I urge you to support the rules as proposed at the August 17,2006 

workshop. Even though these rules will be costly, and change some of the practices our 

company is currently doing, we are connnitted to making them work, and continuing 

improve air quality in ow county. Thank you for your time and attention to my 

Paul Caneron 

President 
>- 

James R Molola Lawrence Moiolo 

420 5 Sycamore Drive 4995 Sycornore Drlve 

(760) 3443140 (760) 3443384 

A Coltforn~a hm~ted Portnersh~p 

1594 GONDER ROAD 

BRAWLEY, CALIFORNIA 92227 

(760) 344-1 919 

Mr. Victor Carrillo, Chairman 

Imperial County Board of Supervisors 

940 West Maim Street 

El Centro , CA 92243 

Re: Support for Revisions to Rules 101,201,202,206,301,420 and Proposed 

Rule 217lRules Affecting Air Qualify for Feed Yards 

Dear Chairman Camllo, 

To begin, I would like to thank the Imperial County Air Pollution Control 

District (APCD) staff for their work on updating existing rules and proposing 

new rules in order to implement SB700, which provides for decreasing air quality 

emissions for Confined .Animal Feeding Operations (CAFO). The process of 

having a Technical Advisory Committee (TAC) that represented the industry in 

the rules formation proved to be beneficial as the draft rule provided at the ~~. ~~-- ~~- ~~ workshop 1s worka~l~for~~~eiiid11~try~il11d~able-todecrease emissions~ for-your ~ ~- 

community. 
Jomes R Moiolo Lawrence Molola 

A Col~forn~o L~m~ted Portnersh~p 

1594 GONDER ROAD 

BRAWLEY, CALIFORNIA 92227 

(760) 344-1 91 9 

Currently our operation employs 30 people year round. Two of those are 

dedicated to mitigating dust by driving a water truck. Ow costs start with labor 

at $7.50 per hour and our employees work a 9hr day. It also costs about $10/hr 

wear and tear on the trucks. We use our trucks year round to control dust. We 

also spent $150,000 on a sprinkler system that would wet the pens to help reduce 

dust when cattle are most active. In seeing the reduction in dust, we decided to 

install a second system at our other yard at another $150,000. We feel that our 

cost have an economic ripple effect in the community with purchasing of parts, 

providing job opportunities, and a commitment to our surrounding environment. 

Our company has an alliance with a local beef processing plant which employs 

over 600 employees. Their economic impact on the local community has many 

effects. 

To conclude, I urge you to support the rules as proposed at the August 17,2006 

workshop. Although some of the measure will be costly and will change the way 

that I currently do business I believe that these rules will work for my operation 

and for our community. Thank you for your time and attention to my 

comments. 

Sincerely, 

Tom Moiola 

Partner 
September 26,2006 

Mr. Victor Carrillo, Chairman 

Imperial County Board of Supervisors 

940 West Main Street 

El Centro, CA 92243 

Re: Support for Revisions to Rules 101,201,202,206,301,420 and Proposed Rule 

217tRules Affecting Air Quality for Dairies 

Dear Chairman Carrillo, 

To begin, I would like to thank the Imperial County Air Pollution Control District 

(APCD) staff for their work on updating existing rules and proposing new rules in order 

to implement SB700, which provides for decreasing air quality emissions for Confined 

Animal Feeding Operations (CAFO). The process of having a Technical Advisory 

Committee (TAC) that represented the industry in the rules formation proved to be 

beneficial as the draft rule provided at the workshop is workable for the industry and able 

to decrease emissions for your community. 

Currently my consulting compaq, NuDairy One, LLC is actively promoting and 

advising several dairymen concerning the advantages of relocating their operations to the 

Imperial Valley. These are substantially large qperations of 2000-3000 cows which 

result in employlnent of 25-30 persons. Related financial considerations are substantial 

as well as tax benefit to Imperial County. Part of my "pitch" to these individuals is that 

Imperial Valley is fiendly and eager to host their business. These are syphisticated 

operators that will be very responsible and practice BMP (Best M-ement Practices) 

such as dust control, nutrient management and manure management. 

To conclude, I urge you to support the rules as proposed at the August 17,2006 

workshop. These . rules work for our community. Thank you for your time and attention 

to my comments. 

dward McGrew 

her, NuDairy One, LLC 
PHILLIP'S CATTLE CO., INC. 

502 East Barioni Blvd. 

P.O. Box 728 * Imperial, CA 92251 

Phone (760) 355-1 175 

September 7,2006 FAX (760) 355-1 174 

Mr. Victor Carrillo, Chairman 

Imperial County Board of Supervisors 

940 West Main Sfreet 

El Centro, CA 92243 

Re: Support for Revisions to rules 101,201,202,206,301,420 and Proposed Rule 217/Rules 

Affecting Air Quality for Feed Yards 

Dear Chairman Carrillo, 

To begin, I would like to thank the Imperial County Air Pollution Control District (APCD) staff 

for their work on updating existing rules and proposing new rules in order to implement SB700, 

which provides for decreasing air quality emissions for Codmed Animal Feeding Operations 

(CAFO). The process of having a Technical Advisory Committee (TAC) that represented the 

industry in the rules formation proved to be beneficial as the draft rule provided at the workshop 

is workable for the industry and able to decrease emissions for you community. 

Currently my operation has three feed yards. Each feed yard has a 4500-gallon water truck that 

pumps approximated 180 gallons per minute. Amount of gallons that can be applied to feed yard 

area daily is 76,500 gallons or 17 loads approximately. Schedule for spraying is approximately 3 

a.m. to 8 p.m. give or take as needed or that is allowed due to unforeseen incidents. The water 

truck driver sprays water directly in pens, on alleys and work areas, as well as dii road ways and 

feed alleys daily. Prior to any sorting or intentional moving of cattle, the driver will water 

heavily in that area to reduce the amount of dust problems. When trucks are down for 

maintenance we will change the hours of the watering schedule to graveyard and pull a water 

truck from another yard to run the night shift. If canals are out we fdl our trucks hm another 

location until it is back and attempt if possible to reduce the amount of pen changes or sorting 

of cattle until canals are full. We also fax in a copy of our 'Wotice of Canal Out" to the Imperial 

County Air Pollution Control District. Our plan for manure removal is to clean pens every 6 to 

12 months annually. 

Our company employs an average of 45 people. We actively support the community with 

donations to schools, 4-H, FFA, the Mid Winter Fau and local athletics. 

To conclude, I urge you to support the rules as proposed at the August 17,2006 workshop. 

Although some of the measure will be costly and will change the way that I currently do business 

I believe that these rules will work for my operation and for our community. Thank you for your 

tie and attention to my comments. 

Ross Je 
Superior CATTLE FEEDERS, LLI tustom tattle Feeding 

6050 Hwy. 111 P. 0. Box IEZB . Callpatria, California 92233 Office I7601 344-7124 

September 15,2006 

Mr. Victor Carrillo, Chairman 

Imperial County Board of Supervisors 

940 West Main Street 

El Centro, CA 92243 

Re: Support for Revisions to Rules 101,201,202,206,301,420 and Proposed Rule 217/Rules 

Affecting Ai- QuaJity for Feed Yards 

Dear Chairman Carrillo, 

To begin, I would like to thank the Imperial county Air Pollution Control District (APCD) staff 

for their work on updating the existing rules and proposing new rules in order to implement 

SB700, which provides for decreasjn~ air quality emissions for Confined Animal Feeding 

Operations (GO). The process of KaviG a ~echnical Advisory Committee (TAC) that 

represented the industry in the rdes formation proved to be beneficial as the draft rule 

provided at the workshop is workable for the industry and able to decrease emissions for your 

community. 

We own and operate feed yard facilities in the north end of the county. We employ 

over 90 employees in the yards, feed mill and offices. For dust control purposes we 

operate 7 water trucks on the various yards. Four of these trucks are 4000 gallons and 

three are 2500-gallon tanks. The trucks operate daily throughout the property as 

needed. We also have sprinkler systems installed at tl~e larger locations. 

All manure is cleaned from the cattle pens regularly by Superior Cattle Feeders 

employees and moved off the premises by commercial fertilizer companies. We employ 

fulltime equipment operators that move the manure from the pens as needed. This 

activity is reported to the Water Quality Control Board. 

In conclusion, I urge you to support the rules as proposed at the August 17,2006 

workshop. Although some of the measures will be costly and will change the way that I 

currently do business I believe that these rules will work for our operation and for our 

community. Thank you for your time and attention to my commenb. 

Robert Lofton 

Member/manager 
Rule in 202.txt

Subject:

SIP package 202

From:

Monica Soucier <monicasoucier@imperialcounty.net>

Date:

Mon, 02 Apr 2007 14:08:13 -0800

To:

David Brown <dabrown@arb.ca.gov>

CC:

Reyes Romero <reyesromero@imperialcounty.net>

David,

Following are four more e-mails with the zipped packages for each rule that was adopted October 2006

Should you have any question please do not hesitate to call me at (760) 428-4606 or my direct line at (760) 

335-3466

Thank you,

Monica N. Soucier

Air Pollution Control Specialist

150 S. 9th Street

El Centro, CA 92243

(760) 482-4606

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