629 Entler .·frenue, Suite 15 

Chico, C4 95928 

(530) 332-9400 

(530) .U2-9417 Mu: 

Gerardo Rios, Chief 

Penni ts Office (AIR-3) 

March 25, 2016 

U.S. Environmental Protection Agency, Region IX 

75 Hawthorne Street 

San Francisco, CA 94105-3901 

Re: Clarification of SIP Submittal for Penn it Regulations 

Dear Mr. Rios: 

W. Jame~ Wagonn 

Air Pollllllon Control Officer 

Robert McLaughlin 

Asst. Air Polfuti.Jn Control Officer 

The Butte County Air Quality Management District (District) is contacting the U.S. 

En\'ironmental Protection Agency Region 9 (U.S. EPA) regarding the District's submittal of 

Rule 400-Permitting Requirenu!nts, Rule 401-Permit Exemptions and Rule 432-Federal Ne11 · 

Source Revie11' for inclusion into the State hnplementation Plan (SIP). The District wants to 

clarify that the submitted rules are intended to fulfill the new source pem1itting program 

requirements and to replace the existing remaining SIP rules that relate to pennitting 

requirements. In the Executive Summary of the rule adoption staff report, we note: -- ... those 

requirements of fi..'deral law are required to he submitted as a re\'ision to the State 

Implementation Plant (SIP), the District re-cod(fied Regulation JV-Permits in May 2011 and 

included all minor and major administrati11

e federal requirements (empJiasis added) into one 

rule, developed a separate rule fhr permit exemptions, and split the State and federal NSR 

requirements into hvo rules . .. 

For your reference, the attached table identifies the existing SIP Rules (most were adopted in the 

mid-11980's) and cross-references to sections of the cunent submitted rules as adopted in 2014 

which serve as updates/replacements. It was never our intention to have duplicative requirements 

in the SIP .. 

If you have any questions regarding this correspondence, please contact me at (530) 332-9400, 

ext. 112. 

Sincerely, 

:z:,'Z: 

Air Pollution Contro] Officer 

Enclosure:. 

cc: 

Cross, Reference Table of Existing SIP Rules to be Replaced with Current SIP 

Submittal Rules 

Carol Sutkus, Manager, South Coast AQ Planning Section, ARB 

T:\Plnnning:\Air Qu;1lity Plmming:'.SIP Dc1Cl1111 c11L s·Suh111ittal liu PL'lm itting: Ruks\EPA SIP Permitting rule clarilkation.doo 
Butte County Air Quality Management District 

Regulation IV Permits SIP Submittal 

Cross Reference of Existing SIP Rules to be Replaced with Current SIP Submittal Rules 

Existing SIP Rule Applicable New Rule Comments 

Reference 

04-04 Exemptions from Rule 40 I-Permit Exemptions As noted in the Staff Report 

Pennit Requirements 

401 General Requirements Rule 400, Sections ], 4.1 , and 

4.4. I; Rule 432, Section I. I 

402 Authority to Construct Rule 400, Sections 4.] and 4.1.4 

403 Permit to Operate Rule 400, Sections 4.2 and 4.4, The requirement fo11 sources 

Section ] . 1 (relating to sources existing prior to ] 982 to 

subject to Title V must comply obtain a Permit to Operate is 

with Rule 400} an artifact of older pe1111itting 

mies and no longer 

applicable. 

405 Permit Conditions Rule 400, Section 5.2.4 

406 Emission Calculations Rule 400, Section 4.3 Existing SIP Rule 434, 

Section 3.1 also includes that 

tI1e APCO retains this 

authority 

407 Anniversary Date Rule 400,. Section 4.6 Term "anniversary date .. has 

been replaced with dearer 

language noting when the 

pe1111it will expire. 

420 Standards for Granting A. Rule 400, Section 4.8 

Applications B. Rule 400, Sections 4.4.3 and 

4.4.4 

C. Rule 400, Sections 4.4.6 

421 Conditional Approval Rule 400, Section 4.4.8 and 

5.2.4 

424 State Implementation Rule 400, Section 4.4.3 

Plan