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 thefollowing form and include it with the rule package you send ARB. Seethe 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 u nderline 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 beincluded 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 ofthe 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 relaxlimits 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, thennew modeling may be required.
ECONOMIC AND TECHNICAL JUSTIFICATION FOR DEVIATIONSFROM EPA POLICIES: The District staff report or other information i ncluded 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 presumptiveRACT (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): 202Date 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 RomeroPhone Number: (760) 482-4606E-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 "Agricultu ral 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 meeti ng 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 provid ed 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/AArea Affected: N/A
Future Year Control Profile Estimate (Provide information on as many years as possible): N/ACALIFORNIA AIR RESOURCES BOARD APCD/AQMD RULE EVALUATION FORM -- Page 2

(Electronic Format)

Baseline Inventory in the SIP for the Control Measu re: 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 Evaluati on 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/APercent 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/Aof 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/AWork Practice Standards in Section(s): N/ Recordkeeping Requirements in Section(s): N/AReporting Requirements in Section(s): N/ACALIFORNIA 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

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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
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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 systemswhich have a maximumImperial 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 Codeof 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 totransport 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 circulationrate 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 extr uding 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) asImperial County Air Pollution Control District Draft Rule 202

202-4 determined by the following ASTM test methods:

E.8.c.1ASTM D 2879-86, "Standard Test Method for Vapor Pressure-Temperature Relationship and Initial Decomposition Temperature of Liquids by Isoteniscope"

E.8.c.2ASTM 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 tocurbs. E.9.b Unheated non-conveyorized, cleaning Equipment: (Does not include control enclosures)

E.9.b.1With an open surface area of 1.0 square meters (1 0.8 sq. feet) or less and an internal volume of 350 liters (92.5 gal.) or less, and

E.9.b.2Using 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.3Less 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 adequatemonthly 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 usageImperial 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 OperationsSources

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.bAny 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 f

or the operation of orchard and citrus grove heaters. In no event shall a permit be denied an operator of such heaters if theheaters 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 systemswhich have a maximum input heat rating of 5,000,000 Btu per hour (gross)or less and are equipped toImperial 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 Codeof 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 totransport 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 circulationrate 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 productionImperial 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 extr uding 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.1ASTM D 2879-86, "Standard Test Method for Vapor Pressure-Temperature Relationship and Initial DecompositionImperial County Air Pollution Control District Rule 202

202-4 Temperature of Liquids by Isoteniscope"

E.8.c.2ASTM 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 tocurbs. E.9.b Unheated non-conveyorized, cleaning Equipment: (Does not include control enclosures)

E.9.b.1With an open surface area of 1.0 square meters (1 0.8 sq. feet) or less and an internal volume of 350 liters (92.5 gal.) or less, and

E.9.b.2Using 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.3Less 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 adequatemonthly 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 SourcesImperial 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 

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, Board Membec? paFbti@rorthi:s item. ~~~m~ts,sh6~~d~e~add?~sse& ~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 LivestockFeed 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 emissionsproduced 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 ofReductions



### APPROVED 

## OCT 102006 Requirements (tonslday) Reductions from Proposed Control Requirements (tonslyear) Pollutant

Uncontrolled Emissioiis (tonslday) ControlledEmissions (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 

### - "...Anagricultural 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 

## 102006e. 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 implementationplan, 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 217 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 FeedThese 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 emissionreductions.
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 

### 102006
5CAFs, 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 feesunder aPermit 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 102006has 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) ControlledEmissionFactor

(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 implementationplan, 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 2.6emissions 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 StaffRe~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 102006due 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 

## 102006LCAFs. 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 and Dairy 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 thelowest 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 46Volatile 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 2004 Cattle Population 

# 1 5.43
Control Efficiency of Mitigation 

# I 25% Measures

VOC Reductions 30.5%

(lbs VOClbeadiday)

(tonslyear) 3,615

7.65 Controlled Emission Factor



### V PUBLIC PARTICIPATION 360,468

14.48
3.78 Controlled VOC Emissions

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 102006
11notices were conducted according to policy thus advertisementswere 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 staffreport 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

## 2006The 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 17loads. Schedulefor 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 '?\Toticeof 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 supportthe rules as proposed at the August 17,2006 worksl~op. Although some ofthe 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 ToroLand & 

### 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 ofrain, 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 ofnzanure buildup. 8. 

### Manure removedfo7-mthe 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 runoffoccu~~s because we are surrounded by be7.m~ and have a large drainage lagoon that we pump all sto~*m water into. I1. 

### El ToroLand & 

### 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 ToroLand & Cattle has38 employees that live in the conzmunity, with an annual Payroll of $

### I,

### 840,000peryear. 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 supportthe 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 131Acres, 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 10Hrs

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 ofFacIllty: EI 

### Toro Land & 

### Cattle Co., Inc. La Brucherie Ranch McCabe Yard 

# LOC~~~OIR: 1407La 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 10Hrs

~ ~ -

~~~ ~ -----

~ 

### 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 

### Schedulefor 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 940West 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 backgroundfor 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 representedthe 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 12,000head 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 Brandenbergfeedlot 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 ofthe 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 owpens 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) 344-1919



### 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 

### .AnimalFeeding 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 systemthat 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, providingjob 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 attentionto my comments.

Sincerely,

Tom Moiola

PartnerSeptember 26,2006

Mr. Victor Carrillo, Chairman Imperial County Board of Supervisors 940 West Main Street El Centro, CA 92243

Re: Supportfor 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 representedthe industry 

### inthe rules formation proved to be beneficial as the draftrule provided at the workshop is workable for the industry and able to decrease emissions for your community. Currentlymy consulting compaq, NuDairy One, LLC is activelypromoting and advising several dairymen concerning the advantages of relocating their operations to the Imperial Valley. These are substantially large qperations of2000-3000 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 individualsisthat 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 theAugust 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) 355-1175 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 CountyAir Pollution Control District (APCD) staff for their work on updating existingrules and proposing new rules in order to implement SB700, which provides for decreasingair quality emissions for Codmed Animal Feeding Operations (CAFO). The process ofhaving a Technical Advisory Committee (TAC) that represented the industry in the rules formation proved to be beneficial as the draft rule provided atthe workshop is workable for the industry and able to decrease emissions for you community. Currentlymy operation has three feed yards. Each feed yard has a 4500-gallonwater truck that pumps approximated 180 gallons per minute. Amount of gallons that can be appliedto 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 intentionalmoving of cattle, the driver will water heavily in that areato 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 

### runthe night shift. If canals are out we fdl our trucks hm another location until it is back and attempt if possibleto 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 12months annually.
Our company employs an average of 45 people. We actively supportthe communitywith donations to schools, 4-H, FFA, the Mid Winter Fau and local athletics.
To conclude, I urge you to supportthe rules as proposed atthe August 17,2006 workshop. Although some ofthe 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 existingrules 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 rdesformation 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 inthe yards, feed milland 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 attl~e larger locations.
Allmanure 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 atthe August 17,2006 workshop. Although some of the measures will be costly and will change the way that I currently do business Ibelieve 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/managerRule 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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