United States Environmental Protection Agency, Region 9 

Air Division 

Technical Support Document 

for 

EPA’s Notice of Rulemaking 

for the 

California State Implementation Plan 

Santa Barbara County Air Pollution Control District’s 

Rule 333, Control of Emissions from Reciprocating Internal Combustion Engines 

Prepared by: Idalia Pérez 

April 2010 
Santa Barbara County Air Pollution Control District (SBCAPCD) 

Submitted Rule 

SBCAPCD Rule 333, Control of Emissions from Reciprocating Internal Combustion Engines 

 Adopted: June 19, 2008 

 Submitted: October 20, 2008 

 Completeness determination: November 18, 2008. 

Previous Rule Submittals 

The District submitted a previous version of this rule on June 19, 1992 and we proposed a 

limited approval, limited disapproval (60 FR 6049) but did not finalize the action. The District 

then submitted another version of this rule on March 10, 1998 and later withdrew the submittal 

on January 18, 2000. 

SIP-Approved Rule 

There is no SIP-approved version of Rule 333. 

Rule Summary 

SBCAPCD Rule 333 regulates emissions of nitrogen oxides (NOx), reactive organic compounds 

(ROC) and carbon monoxide (CO) from internal combustion (IC) engines with a rated brake 

horse power of 50 or greater. 

Section B of Rule 333 indicates the engine categories that are exempt from the Rule. 

Section C of the Rule contains definitions of relevant terms. 

Section D contains requirements for engine identification and monitoring. 

Section E contains the Emission Limits in the Rule. 

Engine Type NOx ROC 

(ppmv) 

CO 

(ppmv) or (% reduction) (ppmv) 

Rich-Burn Noncyclically-loaded spark 

ignited 

50 90 250 4500 

Lean-Burn spark ignited with a rated 

brake horsepower >50 and <100 

200 - 750 4500 

Lean-Burn spark ignited with a rated 

brake horsepower >100 

125 80 750 4500 

Rich-Burn Cyclically-loaded spark 

ignited 

300 - 250 4500 

Compression ignited and dual-fuel 700 40 750 4500 

Section F delineates the requirements of the Inspection and Maintenance Plan. 

Section G contains the Compliance Plan requirements. The owner or operator of a unit subject to 

the emission limits in the Rule must submit, and obtain approval of, a Compliance Plan 

according to the schedule in Section K. 
Section I specifies the Source Testing requirements. 

Section J has the Recordkeeping provisions. 

The Compliance Schedule is specified in Section K. 

Changes in Emissions

According to the Staff Report, the estimated emission reduction due to the June 19, 2008 version 

of Rule 333 is 0.0178 tons of NOx per day. The estimated emissions of ROC will increase by 

0.0001 tons/day. These changes in emissions are based on engines in the 2005 emission 

inventory. 

Rule Evaluation 

Generally, SIP rules must be enforceable (see section 110(a) of the Clean Air Act, hereafter 

CAA); must require Reasonably Available Control Technology (RACT) for major sources in 

nonattainment areas (see CAA §182(b)(2) and (f)); must not interfere with applicable 

requirements, including requirements concerning attainment (see CAA section 110(l)); and must 

not relax existing requirements in effect prior to enactment of the 1990 CAA amendments (see 

section 193). The SBCAPCD regulates an area that is classified as maintenance for the 1-hour 

ozone standard and is in attainment for all criteria pollutants, thus, submitted Rule 333 does not 

have to fulfill RACT requirements. 

Guidance and policy documents that we used to define specific enforceability requirements 

include the following: 

• Issues Relating to VOC Regulation, Cutpoints, Deficiencies, and Deviations (the "Blue 

Book"), US EPA, OAQPS (May 25, 1988). 

• EPA Region IX’s Guidance Document for Correcting Common VOC and Other Rule 

Deficiencies (August 21, 2001, the “Little Bluebook”). 

• State Implementation Plans; General Preamble for the Implementation of Title I of the 

Clean Air Act Amendments of 1990, 57 FR 13498 (April 16, 1992); 57 FR 18070 (April 

28, 1992). 

• State Implementation Plans; Nitrogen Oxides Supplement to the General Preamble for 

the Implementation of Title I of the Clean Air Act Amendments of 1990 (the "NOX

Supplement to the General Preamble"), US EPA, 57 FR 55620 (November 25, 1992). 

SBCAPCD Rule 333 meets some of the necessary requirements listed above. The Rule was not 

reviewed to determine its fulfillment of RACT thus we are not making a statement of its merit in 

this regard. It is a strengthening of the current SIP and will lead to a net decrease in NOx 

emissions when the rule is implemented. The Rule is not adequately enforceable as it gives the 

APCO too much discretion of what is required, lacks clear guidance on source testing parameters 

and lacks adequate follow-up if a portable analyzer reading is above the emission limit. These 

inadequacies are further discussed below. 
Rule Deficiencies 

1. EPA guidance states that director’s discretion may be appropriate if explicit and replicable 

procedures within the rule tightly define how the discretion will be exercised to assure 

emission reductions.1

 Rule 333 includes various provisions allowing for APCO discretion 

that do not follow EPA guidance. Some examples include: 

• Section F.3: If such an engine cannot be operated for portable analyzer emissions 

testing due to mechanical failure or lack of fuel, the monitoring requirement may 

be waived provided written Control Officer approval is obtained prior to the end 

of the quarter (or month, if performing monthly monitoring). 

• Section D.4: The continuous monitoring system may be a continuous emissions 

monitoring system or an alternative approved by the Control Officer.

The Rule should be amended to follow EPA guidance on director’s discretion. One option for 

approvable provisions is to include EPA approval alongside APCO approval. 

2. Section F.3 indicates that portable analyzer reading in excess of the emission limits triggers 

another reading in 15 days and monthly readings for 3 months. These high portable analyzers 

readings should instead trigger a source test within 60 days of the excess emission reading. 

3. Section I.1 indicates that source tests shall be performed at the engine’s maximum load or 

under the engines’ typical duty cycle as demonstrated by historical operation data. This 

should be constrained to the engine’s maximum load or conditions specified in the Permit to 

Operate. The option for testing at the engine’s typical duty cycle should be further defined 

and justified. 

Suggested Rule Improvement 

EPA recommends that the SBCAPCD make the following improvements in the next revision of 

Rule 333: 

1. The emission limits in the Rule should be further strengthened; see for example San Joaquin 

Valley Unified APCD Rule 4702, section 5.1. 

Recommendation 

EPA staff recommends limited approval/disapproval without sanctions of SBCAPCD Submitted 

Rule 333 for incorporation into the California Applicable SIP. 

Attachments 

1. Submitted Rule 333 

2. Staff Report 

 

1

 “Guidance Document for Correcting Common VOC & Other Rule Deficiencies,” EPA Region 9, August 21, 2001 

(the Little Bluebook), pages 17-18.