December 21, 2011 

Ms. Lily Wong 

US EPA, Region 9, Air Division 

75 Hawthorne Street 

San Francisco, CA 94105 

Re: SCAQMD Rule 317 Section 172(e) Fee Equivalent Programs 

Dear Ms. Wong: 

This is in response to your inquiry regarding Rule 317 and, specifically, the programs that the 

SCAQMD is planning to use as “qualified” programs to fund the Rule 317 Section 172 (e) 

fee equivalency account, why they are surplus to the one-hour ozone State Implementation 

Plan (SIP) and certain other pertinent questions. Our response to your inquiry is provided 

below in a question and answer format. 

1) What are the “qualified” programs SCAQMD is planning to use to fund the 

Rule 317 equivalency account? 

As you know, Rule 317 is designed to satisfy the requirements specified in 

Sections 182(e), 182(f) and 185 of the 1990 amendments to the federal Clean Air 

Act (CAA) by utilizing a fee equivalency approach as allowed under Section 

172(e) of the CAA. The rule establishes and maintains a Section 172(e) fee 

equivalency account for each of the two non-attainment basins in the SCAQMD - 

the South Coast Air Basin (SCAB) classified as “Extreme” and the Riverside 

portion of the Salton Sea Air Basin (SSAB) classified as “Severe-17 nonattainment areas. Each basin’s equivalency account is credited with expenditures 

from certain “qualified” programs and debited with Section 185 fees that would 

otherwise be applicable to major stationary sources. Only programs that satisfy 

all criteria listed in Rule 317, subparagraph (c) (1) (A) are considered “qualified” 

and eligible for crediting the fee equivalency account. In response to your 

inquiry, Exhibit A to this letter lists a compilation of programs that will be used to 

pre-fund the equivalency accounts for the SCAB and the Riverside portion of 

SSAB. These programs are typically funded by local, state, and/or federal 

funding. It should be noted that the fee equivalency account will be credited with 

actual expenditures in 2010 and beyond (except that the funding for the Riverside 

portion of the SSAB will include actual expenditures in that basin for 2008 and 

beyond), invested in projects that reduce or facilitate the reduction of VOC and/or 

NOx emissions, and not by the funding that may be available for a given year. 

For illustration purposes, Exhibit A also includes estimates of the actual 

expenditures in 2010 and 2011 for most of the listed programs that will be used to 

prefund the two equivalency accounts as well as the local, state, and/or federal 
Ms. Lily Wong - 2 - December 21, 2011 

funding level contributed. Please note that the availability of additional local, state 

and/or federal matching funds for many of the programs listed in Exhibit A 

allowed the actual expenditures to exceed the funding level estimates included in 

the staff report for the same programs. 

Exhibit B to this letter provides a compilation of programs that meet all criteria in 

subparagraph (c)(1)(A) of Rule 317 and will be used to fund on an on-going basis

the two equivalency accounts in the future. For information purposes, Exhibit B 

also includes the level of funding expected to be available for each of the 

programs. As stated above, however, actual expenditures may vary from the 

funding estimates depending on the availability of additional matching funds from 

local, state or federal sources. 

As part of this letter, we are formally requesting that the programs identified in 

Exhibits A and B be approved as satisfying the requirement of Rule 

317(c)(1)(A)(i). 

2) Why are the programs listed in Exhibits A and B considered “qualified”? 

The programs listed in Exhibits A and B are considered “qualified” because they 

satisfy all criteria listed in subparagraph (c)(1)(A) of Rule 317, as follows: 

a. They satisfy clause (c)(1)(A)(i) of Rule 317 because, as demonstrated 

below, they are all surplus to the approved one-hour ozone SIP, and 

b. They satisfy clause (c)(1)(A)(ii) of Rule 317 because they facilitate VOC 

and NOx emission reductions (in addition to other criteria and toxic 

pollutant emissions) from the mobile source sector (mostly from on-road 

sources and to a limited extent from some off-road sources) in the South 

Coast Air Basin and the Riverside portion of the Salton Sea Air Basin by 

providing incentive funding that advances the state of the mobile source 

technology, improves fuel and engine infrastructure and accelerates fleet 

turnover through vehicle retrofit and/or replacement, and 

c. They satisfy clauses (c)(1)(A)(iii) and (iv) of Rule 317 because the 

equivalency accounts will be credited with actual program expenditures 

incurred during a given year (2010 and beyond for SCAB and 2008 and 

beyond for SSAB) and not the program funding that may be available but 

remain unspent during the same year. US EPA will be able to verify 

compliance with the two clauses through the review of the annual 

equivalency emission reports SCAQMD will be providing pursuant to 

paragraph (c)(5). 

Please also be aware that SCAQMD produces reports for each of the program that 

summarize annual program activities and are available upon request. 
Ms. Lily Wong - 3 - December 21, 2011 

Based on the above analysis, SCAQMD staff concludes that the programs listed 

in Exhibits A and B are “qualified” programs, eligible to fund the Rule 317 

equivalency accounts. 

3) What is the difference between the programs listed in Attachments B and C to 

the February 2011 Final Staff Report for Proposed Amended Rule 317? 

Regarding your query about the difference between Attachments B and C to the 

February 2011 Final Staff Report, Attachment B lists the funding programs that 

staff was able to determine during the rule development process that could meet 

all four criteria of subparagraph (c) (1) (A) of Rule 317 including being surplus to 

the one-hour SIP. Attachment C included all other funding programs; however, 

staff was unable to complete the surplus to the one-hour SIP analysis within the 

time constraints of the rule development process, necessary to list them as 

“qualified” programs under Attachment B. Since the rule adoption, however, 

staff has completed its analysis and determined, as indicated in the response to 

question #4 below, that the programs listed in Attachment C to the February 2011 

Final Staff Report are also surplus to the one-hour SIP. As indicated in the 

response to Question 1 above, the revised list of funding programs that staff 

intends to use to fund the two equivalency accounts on an on-going basis is 

included as Exhibit B to this letter. 

4) Why are the programs in Exhibits A and B surplus to the one-hour ozone SIP? 

The 1997 South Coast AQMP, as amended in 1999, and approved by US EPA in 

April 10, 2000 (65 FR 18903), which was subsequently modified by those 

elements of the 2003 South Coast SIP approved by US EPA in March 10, 2009 

(74 FR 10176) constitutes the one-hour ozone SIP for the SCAQMD. A careful 

evaluation of the base year, future year baseline, and controlled emission 

inventories included in that one-hour SIP will reveal that SCAQMD’s attainment 

demonstration for the one-hour ozone standard does not reference nor rely upon 

the implementation of any of the programs listed in Exhibits A and B. More 

specifically, please examine (1) Table 1-3 of the 2003 AQMP, (2) Tables 3-1 

through 3-5 in Chapter III of the 2003 AQMP, (3) the mobile source control 

measures, including the emission reduction strategies, and underlying 

assumptions associated with each of the mobile source control measures listed in 

Table 4-4, (4) the emission reduction commitments depicted in Tables 4-6 

through 4-8 and Table 4-11 in Chapter IV of the 1997 AQMP, (5) and the 

corresponding elements of the mobile source control measures and emission 

reduction commitments specified in Chapter IV of the 2003 AQMP to the extent 

they were included in the October 24, 2008, proposed approval of the 2003 South 

Coast SIP (74 FR 63408) and subsequently approved by US EPA in March 10, 

2009. Similarly, a careful review of the more detailed emission baselines for 

current and future years included in (6) Appendix III and its attachments of the 

1997 AQMP, and 2003 AQMP will reveal that none of them include a line item or 

assumptions that rely upon the implementation of any of the programs listed in 
Ms. Lily Wong - 4 - December 21, 2011 

Exhibits A and B. (Exhibit C of this letter details the above AQMP references).

Based on the above analysis, SCAQMD staff concludes that the programs 

identified in Exhibits A and B attached to this letter are surplus to the one-hour 

ozone SIP and, therefore, eligible for funding the Rule 317 Section 172(e) fee 

equivalency account. 

5) How will the equivalency account be tracked for the two Basins in the 

SCAQMD? 

Please note that, as acknowledged in Rule 317, because there are two nonattainment air basins in the jurisdictional authority of the SCAQMD, staff would 

like to clarify that it is committed to maintain two separate fee equivalency 

accounts to independently track and demonstrate fee equivalency for each air 

basin. Program expenditures in each basin will be tracked separately and the 

equivalency account for each of the basins will be credited only with that portion 

of program expenditures that is incurred in that basin. Consequently, to satisfy 

the annual reporting obligations to CARB and US EPA specified in paragraph 

(c)(5) of Rule 317, SCAQMD staff commits to prepare and forward two separate 

equivalency demonstrations, one for each of the basins in the SCAQMD. We 

should point out that the internal tracking mechanism to track when and where the 

expenditures are being incurred is already in place. However, please be reminded 

that, as specified in sub-paragraph (c)(1)(C) and paragraphs (c)(4) and (c)(5) of 

Rule 317, any unused portion of the funds (surplus credit for a given year) will be 

carried over to the following year to satisfy the applicable fee obligation of the 

respective air basin and cannot be claimed by another entity to satisfy its Section 

185(e) fee obligation without the explicit consent of the SCAQMD. Only actual 

expenditure will be used for the equivalency demonstration. 

6) Why is the aggregate baseline adjustment appropriate? 

SCAQMD staff is proposing an aggregate baseline adjustment for the universe of 

facilities subject to Rule 317 to address year to year variability displayed in 

annual facility emissions. While there may be several reasons causing the 

variability in emissions, year to year variability in facilities activity levels is 

among the principal ones. The option of adjusting a facility’s baseline was 

provided in the memorandum by William T. Harnett, Director US EPA Air 

Quality Division to Regional Air Division Director dated March 31, 2008 

(Harnett memo). While the Harnett memo referred to facilities with emissions 

that are “cyclical, irregular or otherwise vary from year to year”, no actual 

definition for any of the three terms was proffered. To conform with the intent of 

the guidance provided and for implementation consistency, staff included a 

programmatic adjustment for all facilities subject to Rule 317 to establish their 

baseline using Fiscal Year 2005/2006 and Fiscal Year 2006/2007 emissions as 

reported through SCAQMD’s annual emissions system. This approach provides a 

more realistic emission baseline compared to 2010 emission levels which were 

strongly influenced by the ongoing economic downturn. Further, this approach 
Ms. Lily Wong - 5 - December 21, 2011 

provides a more conservative baseline resulting in a higher facility universe-wide 

Section 185 fee obligation than the one resulting from allowing each facility to 

pick their highest two consecutive years (see Exhibit D to this letter) and avoids 

the uncertainty of defining “cyclical, irregular and/or variable emissions. 

Furthermore, using a programmatic adjustment for calculating baseline, such as 

the one included in Rule 317, satisfies the Harnett memo requirement to adjust an 

alternative baseline for regulatory effect but obviates the need for a facility-byfacility adjustment. Specifically, the Fiscal Year 2006/2007 emissions will be 

adjusted to account for rule effects that occurred subsequent to the 2006/2007 

timeframe including the RECLAIM shave for the universe of Rule 317 facilities. 

This conservative approach to establishing the programmatic Rule 317 baseline 

satisfies the criteria of the Harnett memo and is consistent with the aggregate 

approach for fee equivalency inherent in our rule. 

7) What are the mechanisms that would ensure emissions data integrity and that 

actual emissions do not exceed allowables? 

There are several avenues through which emissions data integrity can and will be 

maintained for Rule 317 purposes. The Rule 317 universe consists of the largest 

facilities in the basin which are also Title V facilities. With very few exceptions, the 

vast majority of all NOx sources in the Rule 317 universe are also in the RECLAIM 

program which requires an annual reconciliation of actual emissions versus emission 

credit holdings to ensure that actual emissions do not exceed allowables. Both Title 

V and RECLAIM facilities are inspected annually to ensure emissions compliance. 

Further, the emissions data used for baseline and subsequent year emissions are 

obtained from information gathered by the Annual Emissions Reporting (AER) 

program, which is audited periodically for data accuracy purposes. The AER 

Program, developed consistent with the state law and embedded in SCAQMD Rule 

301, requires facilities that exceed specific emissions thresholds to report their 

emissions from permitted and non-permitted equipment and processes annually. 

Facilities are also required to pay emission fees for total emissions exceeding any of 

the thresholds specified in Rule 301 for both criteria pollutants, 24 toxic air 

contaminants and ozone depleting compounds. All facilities subject to Rule 317 are 

obligated to report their emissions through the AER program and pay fees 

corresponding to their reported emissions. It should be noted that accuracy of the 

reported emissions through the AER program is critical for the SCAQMD because the 

emission fees collected pursuant to the reported emissions constitute one of the three 

most significant revenue sources for the agency. More importantly, however, 

SCAQMD largely relies on emissions data compiled through the AER program in 

developing its emissions inventories and control measures for its Air Quality 

Management Plan and its revisions, as well as developing new rules and amendments 

to existing rules to achieve air quality standards in the Basin. As stated above, 

periodic audits are used to ensure accuracy of data submitted. Please be aware that 

facilities are obligated to rectify any underreporting discovered through audits and 

pay penalties for the underreported portion of their emissions. Furthermore, please 
Ms. Lily Wong - 6 - December 21, 2011 

also be aware that the reporting of actual emissions, through the AER program in 

excess of allowables would constitute facility admission, in writing, of violation of 

District rules and/or permit conditions that limit the facility emissions and would 

invite swift enforcement action against the facility that would include issuance of a 

Notice of Violation and imposition of severe monetary and other penalties. 

Therefore, we can confidently state that these measures, that are already in effect, 

provide adequate assurance that actual emissions will not exceed allowable 

emissions. 

Based on the above analysis, we can assert that the baseline emissions values for the 

Fiscal Years 2005/06 and 2006/07 will be the lower of actuals or allowables. Our data 

integrity approach also addresses facilities that do not have emissions data for Fiscal 

Years 2005/2006 and 2006/2007 or that started operation subsequent to Calendar 

Year 2007. For these facilities, their Baseline emissions will be their Calendar Year 

2010 actuals, not to exceed allowables.

I hope you find our responses helpful. If you have any questions on this matter, please 

contact Dr. Laki Tisopulos, Assistant Deputy Executive Officer, at (909) 396-3123. 

 Sincerely, 

 Elaine Chang, DrPH 

 Deputy Executive Officer 

 Planning, Rule Development & Area Sources 

cc: Kurt Karperos, CARB 

Exhibit A - Qualified Programs and Estimated Actual Expenditures for 2010 and 2011 Pre-Funding 

the Section 172(e) Fee Equivalency Account 

Exhibit B – Qualified Programs Providing On-Going Funding For Post-2011 to Section 172(e) Fee 

Equivalency Account 

Exhibit C – AQMP references 

Exhibit D – Rationale for the Alternative Baseline in Rule 317 
A- 1 

EXHIBIT A – QUALIFIED PROGRAMS AND ESTIMATED ACTUAL EXPENDITURES FOR 2010 AND 2011 PRE- FUNDING THE SECTI

ACCOUNT 

Name Date of Award Expenditure Year One-time/ Ongoing Actual Expenditure In SOCAB 

U.S. EPA DERA

School Bus Replacement 6/30/2010 2011 One-time 

$299,000 (US EPA) 

$8,650,734 (local) 

$40,740,000 (state) 

U.S. EPA DERA Earmark

LNG Truck Replacement 11/6/2009 2010/2011 One-time 

$6,238,000 (US EPA) 

$10,675,000 (local) 

$15, 250,000 (state) 

Crane, Shore Power, Off Road 4/21/2010 2011/2012 One-time 0 

U.S. EPA Emerging Technologies

Truck Retrofits/SCRT 4/28/2009 2010 One-time $691,260 (US EPA + local) Truck Retrofits-SCRT (ARRA) 8/31/2009 2011 One-time $1,325,094 (US EPA + local) Truck Retrofits-SCCRT (ARRA) 8/31/2009 2011 One-time $2,125,746 (US EPA + local) 
A- 2 

Name Date of Award Expenditure Year One-time/ Ongoing Actual Expenditure In SOCAB 

U.S. DOE Clean Cities

ARRA-LNG Truck Replacement 11/6/2009 2010 One-time 

$2,746,000 (DOE) 

$4,165,000 (local) 

$6,100,000 (state) 

New LNG Station Ontario, CA 3/12/2010 2010/2011 One-time 0 UPS Ontario-Las Vegas LNG.... (ARRA) 12/18/2009 2010/2011 One-time 0 

AB2766

Local Governments* FY 2009/2010 Ongoing $18,866,355 (local) MSRC* 2010 Ongoing $11,515,865 (local) 

ARB AB118 Program

Hybrid Truck and Bus Voucher Incentive Project (HVIP) 2010 One-time $1,500,000 (local) $9,200,000 (state) Clean Vehicle Rebate Program (CVRP) 2010 One-time 0 Lawn Mower 2010 One-time $816,000 (local) 
A- 3 

Name Date of Award Expenditure Year One-time/ Ongoing Actual Expenditure In SOCAB 

California Energy Commission Funding

LNG Truck Replacement 7/9/2010 2011 One-time $1,550,000 (local) NG Infrastructure: South Coast Air Basin 5/17/2010 2011 One-time 0 

SCAQMD Clean Fuels Program 2010 Ongoing $7,835,424 (local) Carl Moyer Memorial Air Quality Standards Attainment Program 2010

2011

OngoingOngoing

tbd

Goods Movement Emission Reduction Program (Proposition 1B/2006) 2010

2011

OngoingOngoing

$62,136,000 $37,812,000 

*: Based on reported expenditures by local governments and MSRC that were spent in VOC/NOx emission reduction related projects.
B- 1 

EXHIBIT B – QUALIFIED PROGRAMS PROVIDING ON-GOING FUNDING FOR POST-2010 TO SECTION 172(e) FEE EQUIV

Name

Date of 

Award 

Initial Year * 

of Expenditure 

Estimated

Timeframe 

for Full 

Achievement 

of

Reductions 

Reduction 

in District 

or Airshed 

Explanation of 

benefit to ozone 

reduction 

Project Descrip

U.S. EPA DERA EarmarkHeavy Duty Truck Replacement 9/25/2009 2008/2009 2009 - 2014 District 

Replace 132 heavydiesel drayage trucoperating in and arthe twin ports of LAngeles and Long California, with netrucks that are certCARB.

Heavy Duty Truck Replacement 9/25/2009 2010/2011 2010 - 2016 District 

Replace heavy-dutdrayage trucks opein and around the tports of Los AngelLong Beach Califowith new LNG truare certified by CA

U.S. DOE Transportation Electrification
B- 2 

Name

Date of 

Award 

Initial Year * 

of Expenditure 

Estimated

Timeframe 

for Full 

Achievement 

of

Reductions 

Reduction 

in District 

or Airshed 

Explanation of 

benefit to ozone 

reduction 

Project Descrip

Plug-in Hybrid Electric Medium.. (ARRA) 12/14/2009 2013 2013-2018 

122

Vehicles in 

District, 

Remainder

Nationwide 

R&D to demonstrate 

hybrid systems in 

medium-duty vehicles; 

estimate 30% 

reduction in NOx and 

VOC 

Develop plug-in hytechnology for medduty vehicles, creaproduction capabilestablish a supportcharging infrastrucincludes demonstraprogram of 378 ve

U.S. DOE Clean CitiesNG Taxi Cabs & Shuttle Vans... 6/24/2010 2010 

45 Natural 

Gas Taxicabs 

deployed, 

34 NG vans 

to be 

completed by 

early 2011 

District

Natural gas passenger vehicles and vans have lower nonmethane hydrocarbon and NOx emissions than their gasoline counterparts. In addition, this sector has been replacing taxicabs and vans with older, higher polluting gasoline vehicles. 

Deploy 45 NG taxand 34 NG shuttle for operation at macommercial airportserving Southern California
B- 3 

Name

Date of 

Award 

Initial Year * 

of Expenditure 

Estimated

Timeframe 

for Full 

Achievement 

of

Reductions 

Reduction 

in District 

or Airshed 

Explanation of 

benefit to ozone 

reduction 

Project Descrip

Heavy Duty NG Drayage Truck ... (ARRA) 

12/18/2009 2010/2011 2010- 2016 District 

Replace HD diesel drayage trucks opein and around the PLB and LA with Ltechnology; providoutreach and trainialternative fuel technology. 

U.S. Department of TransportationDiesel Emissions Reduction in the South Coast AQMD (SAFTEA-LU) 

6/15/2010 2011 2011 - 2016 District Replace diesel truc

LNG trucks 

CARB AQIP Funding**Lawnmower Exchange 2010 2010 - 2018 District 

AQMD residents mexchanging an oldoperable gasolinepowered lawn mowpurchase a new elelawnmower. 

Hybrid VIP 2010/2011 Summer 2011 District 

Voucher incentive program to purchahybrid trucks and b

California Energy Commission Funding
B- 4 

Name

Date of 

Award 

Initial Year * 

of Expenditure 

Estimated

Timeframe 

for Full 

Achievement 

of

Reductions 

Reduction 

in District 

or Airshed 

Explanation of 

benefit to ozone 

reduction 

Project Descrip

Transportation/ Electrification 9/2/2010 2013 2013-2018 

122

Vehicles in 

District, 

Remainder

Nationwide 

R&D to demonstrate hybrid systems in medium-duty vehicles; estimate 30% reduction in NOx and VOC 

Develop plug-in hytechnology for medduty vehicles, creaproduction capabilestablish a supportcharging infrastrucincludes demonstraprogram of 378 ve

Ports Clean Truck FundingPort of Long Beach 3/24/2010 2010 2010 - 2015 District 

Replace HD diesel drayage trucks opein and around the PLong Beach with Ltechnology. 

Port of Los Angeles 3/5/2010 2010 2010 - 2015 District 

Replace HD diesel drayage trucks opein and around the PLos Angeles with Ltechnology. 

SCAQMD Clean Fuels ProgramElectric & Hybrids On-going 2010-2020 District Clean Fuels projec

including hybrid anelectric vehicle 

Hydrogen & Fuel Cells On-going 2010-2020 District 
B- 5 

Name

Date of 

Award 

Initial Year * 

of Expenditure 

Estimated

Timeframe 

for Full 

Achievement 

of

Reductions 

Reduction 

in District 

or Airshed 

Explanation of 

benefit to ozone 

reduction 

Project Descrip

Engine Technology On-going 2010-2020 District technologies, 

infrastructure and deployment, hydroinfrastructure and mfuel cell technologemissions control technologies, engintechnologies, and stationary clean futechnologies. 

Infrastructure & Deployment On-going 2010-2020 District Emission Controls On-going 2010-2020 District Stationary On-going 2010-2020 District Health Impacts On-going 2010-2020 District Emission Studies On-going 2010-2020 District Technology Transfer On-going 2010-2020 District AB2766Local Governments 

Post

2008/2009

MSRC 

–2011 and 

beyond 

Carl Moyer Memorial Air Quality Standards Attainment Program On-going On-going Goods Movement Emission Reduction Program (Proposition 1B/2006) On-going On-going 
B- 6 

* The Section 172(e) equivalency account will only be credited with actual expenditures in 2010 and beyond, o the extent expenditures have not bee

Exhibit A. 
D- 1 

EXHIBIT D 

RATIONALE FOR THE ALTERNATIVE BASELINE IN 

RULE 317 

1) Is the Selection of FY 2005-06 and FY 2006-07 Emissions Reasonable for 

Establishing an Alternative Baseline? 

2) Does the Ten Year AER Emissions Data of 2000-2010 Support an 

Aggregate Baseline Adjustment? 

3) Comparison of Alternative Baselines – Annualized Average of FY’s 2005-

2007 vs. Highest 2 Consecutive Years in the past Ten Years (2-in-10) 
D- 2 

RATIONALE FOR THE ALTERNATIVE BASELINE IN RULE 317 

1) Is the Selection of FY 2005-06 and FY 2006-07 Emissions Reasonable for Establishing 

an Alternative Baseline?

To avoid establishing an emissions Baseline reflecting the economically depressed activity 

levels of 2010, staff has explored the alternative Baseline concept provided by the Harnett 

memo, and specifically focused on alternative years that more closely reflect prerecessionary activity levels. 

The following page duplicates Figure 6 of the February 2011 Rule 317 staff report and 

includes the data used to generate the graph. The graph demonstrates why FY 2005-06 and 

FY 2006-07 were chosen as pre-recessionary years with higher aggregate fuel and solvent 

usage. The fuel and solvent usage information, which is a good surrogate for economic 

activity for stationary sources for a given year, is submitted to the District annually under the 

Annual Emissions Reporting (AER) Program by all major stationary sources and is used for 

this analysis. The AER Program, developed consistent with state law and embedded in 

SCAQMD Rule 301, requires facilities that exceed specific emissions thresholds to report 

their emissions from permitted and non-permitted equipment and processes annually. 

Facilities are also required to pay emission fees for total emissions exceeding any of the 

thresholds specified in Rule 301 for both criteria pollutants and 24 toxic air contaminants and 

ozone depleting compounds. All facilities subject to Rule 317 are obligated to report their 

emissions through the AER program and pay fees corresponding to their reported emissions. 

Also included are employment data for California and the four-county area that comprises 

the SCAQMD (Figure 3 and Figure 4 of the February 2011 Rule 317 Staff Report). 

Employment data clearly show the impact of the recession beginning in the second quarter of 

calendar year 2008.

Careful evaluation of the three figures reveals that selecting the average of the emissions 

reported for FY 2005-06 and FY 2006-07 is reasonable for the purposes of establishing an 

alternative Baseline since it closely reflects pre-recessionary activity levels. 
D- 3 

Figure 6 from February 2011 Rule 317 Staff Report 

Raw Data for Figure 6 

2000 2001 2002 2003 2004 2005 2006 2008 2009 

R317-Gaseous 

Fuel (mmscf) 563,945 525,653 424,246 409,583 421,673 445,711 457,983 489,232 440,632 

R317-

Coating/Solvent 

(Mgal) 8,400 12,349 13,886 12,886 15,172 14,955 14,654 10,363 7,940 

Normalized Data for Figure 6 

2000 2001 2002 2003 2004 2005 2006 2008 2009 

R317-Gaseous 

Fuel 1 0.9 0.8 0.7 0.7 0.8 0.8 0.9 0.8 

R317-

Coating/Solvent 1 1.47 1.65 1.53 1.81 1.78 1.74 1.23 0.95 

(Data source: SCAQMD AER data for years 2000-2010) 

0

0.2

0.4

0.6

0.8

1

1.2

1.4

1.6

1.8

2

2000 2001 2002 2003 2004 2005 2006 2008 2009

Gaseous Fuel & Coating/Solvent Usage Trends

For PR317 Facilities

R317-Gaseous Fuel R317-Coating/Solvent

R317-

R317-
D- 4 

Figure 3 from February 2011 Rule 317 Staff Report 

California Employment 

Figure 4 from February 2011 Rule 317 Staff Report 

Four-county Employment 

15.2

15.4

15.6

15.8

16

16.2

16.4

16.6

16.8

17

17.2

JanͲ07

AprͲ07

JulͲ07

OctͲ07

JanͲ08

AprͲ08

JulͲ08

OctͲ08

JanͲ09

AprͲ09

JulͲ09

OctͲ09

JanͲ10

AprͲ10

JulͲ10

OctͲ10

Millions

Source: http://www.labormarketinfo.edd.ca.gov/?pageid=164

6.8

7.0

7.2

7.4

7.6

7.8

8.0

JanͲ07

MarͲ07

MayͲ07

JulͲ07SepͲ07

NovͲ07

JanͲ08

MarͲ08

MayͲ08

JulͲ08SepͲ08

NovͲ08

JanͲ09

MarͲ09

MayͲ09

JulͲ09SepͲ09

NovͲ09

JanͲ10

MarͲ10

MayͲ10

JulͲ10SepͲ10

Millions

Source: http://www.labormarketinfo.edd.ca.gov/?pageid=164
D- 5 

2) Does the Ten Year AER Emissions Data of 2000-2010 Support an Aggregate 

Baseline Adjustment?

Section 185(b)(2) of the 1990 Amendment to the CAA requires that major stationary 

sources compute their Baseline as (emphasis added):

BASELINE AMOUNT.—For purposes of this section, the baseline amount shall be 

computed, in accordance with such guidance as the Administrator may provide, as the 

lower of the amount of actual VOC emissions (‘‘actuals’’) or VOC emissions allowed 

under the permit applicable to the source (or, if no such permit has been issued for the 

attainment year, the amount of VOC emissions allowed under the applicable 

implementation plan (‘‘allowables’’)) during the attainment year. Notwithstanding the 

preceding sentence, the Administrator may issue guidance authorizing the baseline 

amount to be determined in accordance with the lower of average actuals or average 

allowables, determined over a period of more than one calendar year. Such guidance 

may provide that such average calculation for a specific source may be used if that 

source’s emissions are irregular, cyclical, or otherwise vary significantly from year to 

year.

For sources with “cyclical, irregular or emissions that otherwise vary significantly from 

year to year” the following guidance on alternative methods of computing the Baseline 

was provided by the Administrator1:

“...sources may generally use the relevant source records for any 24-consequtive month 

period in the last 10 years (‘2-in-10’ concept) to calculate an average actual annual 

emissions rate (tons per year).” 

Should sources in the SOCAB use their respective attainment year emissions to 

compute their Baselines? They would have do so, unless it could be shown that their 

annual emissions are “irregular, cyclical, or otherwise vary significantly from year to 

year.” There has been much discussion about how a source that has irregular, cyclical, 

or otherwise significantly varying emissions from year to year would be identified so 

that it might establish an alternative Baseline. 

One approach is to identify what a source that does not have irregular, cyclical, or 

otherwise significantly varying emissions from year to year would look like based on 

annual emissions reporting. This can be done, since a sources emissions profile is 

either irregular, cyclical, or otherwise significantly varying from year to year or simply 

regular or unvarying from year to year. Such a hypothetical “regular” emissions source 

1 US EPA memo: “Guidance on Establishing Emissions Baselines under Section 185 of 

the Clean Air Act (CAA) for Severe and Extreme Ozone Non-attainment Areas that Fail 

to Attain the 1-hour Ozone NAAQS by their Attainment”, William T. Harnett, Director, 

dated March 21, 2008
D- 6 

would have the characteristic of a uniform annual emissions profile, as shown in Figure 

A below: 

Figure A. Uniform Emissions Profile 

Thus a source that has a uniform emissions profile is definitely not indicative of annual 

source emissions that are irregular, cyclical, or otherwise significantly varying emissions 

from year to year. By corollary, this implies that sources with an emissions profile 

deviating from a uniform emissions profile are irregular, cyclical, or otherwise have 

annual emissions that vary significantly from year to year.

The following test statistic (V) can be used to numerically confirm that a given emissions 

profile is either varying or un-varying: 

V = Variation in Emissions (or Irregularity) = Range of Emissions

 Median Emissions Value 

The test statistic is straight forward, easy to calculate and intuitive. It uses the actual 

middle value (median) of the range of actual emissions values and measures this central 

tendency value against another easily calculated variable, the range, which takes in the 

span of actual emissions over the given ten year period. For the uniform emissions 

profile, V = 0, since the range of emissions (defined as the highest actual emissions value 

Annual Rule 317 Emissions 

(T )

Year
D- 7 

minus the lowest actual emissions value) will be equivalent to zero, regardless of the 

median value. 

For the current 2-in-10 analysis and determination of source emissions profiles in the SOCAB, 

112 sources, were identified from the District’s AER records system, with a complete ten years 

worth of (NOx and VOC) emissions data. Since Rule 317, in accordance with EPA’s guidance2

,

allows a major source to aggregate NOx and VOC emissions, for the purposes of this analysis 

annual NOx and VOC emissions for each source are aggregated and the resulting value is 

reported as a single figure in tons on an annual basis. For each of the 112 sources that are 

subject to this analysis, Figure B shows their annualized emissions for the most recent 10 year 

period, the median annualized emissions value, the range of the annualized emissions values and 

the test statistic V. 

For the purposes of this analysis Annual Emissions Report (AER) emissions data for the most 

recent ten year time span was used. Specifically emissions from the following AER years were 

used: 

 Fiscal Year (FY) 2000-2001 (from July 1, 2000 through June 30, 2001) 

 FY 2001-2002 (from July 1, 2001 through June 30, 2002) 

 FY 2002-2003 (from July 1, 2002 through June 30, 2003) 

 FY 2003-2004 (from July 1, 2003 through June 30, 2004) 

 FY 2004-2005 (from July 1, 2004 through June 30, 2005) 

 FY 2005-2006 (from July 1, 2005 through June 30, 2006) 

 FY 2006-2007 (from July 1, 2006 through June 30, 2007) 

 Calendar Year (CY) 2008 (from January 1, 2008 through December 31, 2008) 

 Calendar Year (CY) 2009 (from January 1, 2009 through December 31, 2009) 

 Calendar Year (CY) 2010 (from January 1, 2010 through December 31, 2010) 

This time span excludes the six month period from July 1, 2007 through December 31, 2007 

since only six months of emissions data is available for this six-month transitional period, during 

which a switchover in tracking emissions from fiscal year (FY) to calendar year (CY) was 

implemented. 

Note that for all sources the test statistic V is greater than zero indicating that none of the sources 

has a uniform distribution of annualized emissions for the given ten year period. Furthermore, 

both emissions data and results have been rounded to the nearest ton, the level of significance 

measure, as provided for in both the CAA and Administrator guidance. In addition, the CAA 

does not require a demonstration of irregular, cyclical, or otherwise significantly varying 

emissions profile from year to year beyond the attainment year. Only that this be demonstrated 

for the ten year span immediately preceding and/or including the attainment year. This has been 

shown to be so for the 112 sources in this analysis. Visually, Figure C is a histogram showing V 

values for all 112 sources blocked into 20% increments of V values. Note the obvious variability 

2 US EPA memo: “Guidance on Developing Fee Programs Required by Clean Air Act 

Section 185 for the 1-hour Ozone NAAQS”, Attachment C, Point B, Stephen D. Page, 

Director, dated January 5, 2010)
D- 8 

of the sources. While most sources have a V value between 40 and 120%, some sources have V 

values exceeding 300%. This histogram shows very graphically the large amount of variability 

in Rule 317 source emissions over a span of 10 years.

Next, we will show that the average of the fixed FY 2005-06 and FY 2006-07 is at least as 

conservative a Baseline, if not more, than the allowed 2-in-10 or any 2-in-P years (where P  2).
D- 9 

Figure B. Data and Analysis Results for 112 Sources With a Complete 10 Years of Reported Emissions(Source Aggregated NOx and VOC emissions)

Source FY00-01 FY01-02 FY02-03 FY03-04 FY04-05 FY05-06 FY06-07 CY2008 CY2009 CY2010 medS1 18 19 16 19 17 17 18 15 15 14 S2 30 28 25 32 32 33 30 35 33 33 S3 40 84 44 50 73 67 57 50 26 30 S4 294 388 134 131 133 99 93 90 67 84 S5 108 96 81 87 88 52 40 21 23 21 S6 143 189 204 205 214 230 229 202 153 157 S7 198 71 30 55 75 48 44 28 31 35 S8 463 481 367 279 163 183 172 135 78 75 S9 192 116 98 116 84 77 91 98 97 79 S10 190 170 143 75 63 67 64 73 72 65 S11 34 33 30 27 29 26 21 22 33 29 S12 53 74 56 84 83 76 60 47 33 36 S13 59 77 61 58 65 58 71 60 33 30 S14 109 57 62 60 48 35 42 42 38 42 S15 28 17 16 25 33 34 24 21 18 17 S16 18 18 15 15 15 14 13 13 16 13 S17 45 36 63 46 77 86 50 44 15 37 S18 44 40 45 57 64 52 52 22 17 22 S19 22 25 18 15 16 19 22 25 28 30 S20 32 41 26 27 25 25 29 33 30 16 S21 53 40 29 23 27 22 20 14 15 17 S22 196 203 187 186 187 183 180 208 197 188 S23 89 85 90 102 118 97 104 54 49 60 S24 41 19 30 29 40 25 25 14 13 15 S25 45 44 45 51 45 42 38 40 45 46 S26 37 48 65 62 55 49 53 40 41 44 S27 101 96 122 120 123 103 71 88 32 47 S28 43 40 41 37 48 47 46 41 40 34 S29 50 32 75 35 37 39 40 30 35 33 S30 29 22 18 19 23 25 27 29 26 26 S31 116 138 147 102 104 105 130 109 117 124 S32 34 21 21 25 26 17 20 25 20 20 S33 120 128 110 126 135 113 106 86 79 88 
D- 10 

Source FY00-01 FY01-02 FY02-03 FY03-04 FY04-05 FY05-06 FY06-07 CY2008 CY2009 CY2010 medS34 29 39 37 52 35 25 21 18 16 14 S35 119 118 115 114 102 98 85 106 111 120 S36 49 47 54 65 55 68 63 67 51 51 S37 28 27 25 18 26 30 27 21 19 21 S38 26 15 15 15 26 23 23 20 15 22 S39 44 39 33 30 26 24 25 22 20 21 S40 339 328 330 297 319 325 339 270 346 348 S41 13 21 19 20 19 15 16 17 16 16 S42 259 199 178 189 151 185 165 147 115 186 S43 38 36 31 35 36 31 14 14 14 19 S44 31 20 22 17 19 27 28 30 32 32 S45 21 25 30 48 42 46 52 51 40 55 S46 19 15 27 31 39 51 56 36 33 43 S47 76 66 54 61 38 41 41 37 40 43 S48 102 139 125 112 128 126 122 141 122 100 S49 22 16 31 32 43 43 44 39 34 42 S50 16 22 19 17 23 32 33 42 50 50 S51 92 102 90 92 111 92 87 108 70 84 S52 23 34 29 27 26 29 36 30 20 12 S53 115 109 112 111 103 100 102 108 106 115 S54 11 11 11 11 11 11 11 11 11 10 S55 68 66 60 55 66 56 49 54 77 64 S56 22 20 15 15 25 43 19 23 19 19 S57 13 20 16 17 18 21 26 21 21 18 S58 48 32 23 31 16 20 29 27 19 22 S59 50 31 19 18 17 15 16 15 15 16 S60 63 40 41 32 31 25 17 15 12 12 S61 42 46 51 47 36 28 33 18 23 25 S62 26 24 31 25 29 28 26 29 27 30 S63 52 47 52 54 52 45 47 47 45 38 S64 1,308 404 124 20 22 43 29 42 26 13 S65 901 100 66 74 63 47 40 55 43 38 S66 1,708 608 288 153 119 71 54 108 73 43 S67 639 295 57 42 40 41 50 20 39 14 
D- 11 

Source FY00-01 FY01-02 FY02-03 FY03-04 FY04-05 FY05-06 FY06-07 CY2008 CY2009 CY2010 medS68 850 197 124 49 36 53 26 36 39 18 S69 111 60 44 29 27 27 22 20 18 17 S70 19 18 20 22 22 21 20 17 21 18 S71 116 40 54 58 128 101 83 124 97 91 S72 26 43 44 25 17 17 17 14 16 15 S73 104 115 153 149 138 138 154 149 142 134 S74 46 49 55 54 54 62 47 40 15 21 S75 82 47 65 43 42 27 24 26 28 22 S76 22 23 18 17 24 24 24 24 24 14 S77 57 55 66 68 53 54 59 51 88 33 S78 21 48 48 34 55 47 41 39 28 24 S79 441 374 442 390 405 375 471 362 373 386 S80 2,167 1,897 1,860 2,047 1,863 1,638 1,486 1,479 1,210 1,190 1S81 74 56 62 56 46 38 29 29 31 26 S82 26 28 35 46 45 42 43 24 25 33 S83 89 79 178 160 128 113 92 91 75 90 S84 728 234 335 217 176 133 124 160 155 146 S85 651 176 111 145 78 69 76 80 92 87 S86 29 30 31 26 29 34 36 54 49 37 S87 1,369 1,244 1,468 1,424 1,488 1,446 1,402 1,388 1,322 1,366 1S88 22 21 27 28 27 24 27 23 16 21 S89 286 258 221 265 279 216 292 297 252 252 S90 91 92 57 92 48 26 31 42 18 24 S91 27 38 37 37 38 44 66 56 59 58 S92 253 192 224 183 217 233 245 192 182 162 S93 51 57 54 55 47 57 42 24 26 30 S94 108 30 22 73 84 81 87 85 75 51 S95 41 137 29 63 109 64 42 21 58 36 S96 49 49 22 21 24 26 27 25 27 42 S97 37 55 43 39 50 50 48 47 49 44 S98 89 119 126 107 129 118 113 105 109 117 S99 160 204 242 177 139 165 133 146 177 183 S100 115 114 125 124 128 133 141 138 139 144 S101 50 56 59 79 84 81 90 52 57 30 
D- 12 

Source FY00-01 FY01-02 FY02-03 FY03-04 FY04-05 FY05-06 FY06-07 CY2008 CY2009 CY2010 medS102 15 14 14 15 14 18 17 19 18 18 S103 18 18 13 16 13 15 15 14 13 13 S104 22 23 21 18 16 15 16 15 17 17 S105 27 17 15 14 15 12 15 14 16 16 S106 400 247 62 54 56 58 47 50 49 50 S107 13 70 72 77 62 48 57 54 44 43 S108 81 65 76 55 52 55 52 53 56 51 S109 594 529 505 547 496 519 465 441 451 431 S110 964 852 890 918 825 886 914 968 895 799 S111 52 22 24 24 25 22 23 21 23 25 S112 158 162 128 126 132 133 143 149 126 129 
D- 13 

5

23

17

10

17

10

7

2

6

1 1

2

0

05

10152025

20% 40% 60% 80% 100% 120% 140% 160% 180% 200% 220% 240% 260% 

N

u

m

b

e

r

o

f

S

ou

r

c

e

s

V (%) = Source Emissions Variation = ( Emissions Range 2000Ͳ2010 / Emissions Median 2000Ͳ2010 ) x 100

Figure C. Rule 317 Major Sources Emissions Variation 2000Ͳ2010 (112 Sourc
D- 14 

3) Comparison of Alternative Baselines – Annualized Average of FY’s 2005-2007 

vs. Highest 2 Consecutive Years in the past Ten Years (2-in-10)

Rule 317 implements Section 185 of the Clean Air Act by using an alternative Baseline 

consisting of the annualized average of a source’s FY 2005-06 and FY 2006-07 

emissions. Under an alternative definition, the Harnett memo Baseline can consist of the 

average of any two consecutive years in the last ten years (2-in-10).

It can be shown, with mathematical certainty, that any alternative Baseline that allows a 

source to choose the two consecutive years over which Baseline emissions are averaged 

will always result in a higher Baseline and a lower Rule 317 source fee obligation in 

contrast to an annualized Baseline where the two consecutive years over which emissions 

are averaged is fixed. 

Given that, 

f is the annualized average of a given source’s emissions , and 

X represents the annual emissions of the source in a given fiscal (or calendar) year, and 

Y represents the annual emissions of the source in the next immediately consecutive 

fiscal (or calendar) year, and 

Xirepresents the annual emissions of the source in a given fixed fiscal (or calendar) year, 

and

Yi represents the annual emissions of the source in the next immediately consecutive 

fiscal (or calendar) year following Xi.

Then, f(Xi,Yi)  f(X,Y) , where X, Y, Xi and Yi are all from the same set of years 

This result holds in all cases since a source, given the option, can always choose an 

emissions Baseline annualized over the two highest consecutive emissions years. In 

which case these two years will exceed the emissions Baseline of any given alternative 

two fixed years or they will be the same as the two fixed years. In no case will the 

annualized emissions averages for a fixed two year annualized emissions average exceed 

a “2-in-P years” annualized emissions average. Consequently a source will always incur 

a higher or same Rule 317 source fee obligation with a fixed two year annualized 

emissions average. 

The comparative analysis below uses actual emissions information form 112 

facilities/sources subject to Rule 317 to demonstrate the point. For the purposes of this 

comparative analysis an emissions data set that spans the ten year time period from July 

1, 2000 through December 31, 2010, was used. For the spanning set of years in this 

analysis (from FY 2000-01 thorough CY 2010) the following nine possible discrete two 

year consecutive pairs (and consequently 2 year averaged emission pairs) exist: FY 

2000-01/2001-02, FY 2001-02/2002-03, FY 2002-03/2003-04, FY 2003-04/2004-05, FY 

2004-05/2005-06, FY 2005-06/2006-07, FY 2006-07/CY 2008, CY 2008/09 and CY 

2009/10. Therefore, over a ten year span, nine two-year consecutive averages are 

available for a facility to select as an alternative 2-in-10 Baseline as compared to the 

fixed Baseline (average of FY 2005-06/2006-07) as currently defined in Rule 317. For 

this10-year span, there were 112 sources, that had emissions of either NOx or VOC, or 
D- 15 

both that were 10 tons or more in at least one of the years and in addition had emissions 

in all the span years. As such this data set is most representative for a 2-in-10 Baseline 

analysis. 

Figure D below summarizes the resulting emissions in tons/year for both the Rule 317 

Baseline (R) and the alternative highest 2-in-10 Baseline (H). H is calculated by 

assuming that for the 2-in-10 Baseline a source, given the option, will pick the years 

yielding the highest averaged emissions value and therefore resulting in the lowest annual 

Rule 317 fee liability for all future assessment years. The row (H-R) shows the 

additional increase in the aggregate Baseline (and therefore a reduced fee obligation) for 

sources where the alternative Baseline (H) is used instead of the current rule defined 

Baseline (R). 

This demonstrates that use of the alternative highest 2-in-10 Baseline (H) compared to 

the fixed 2-in-10 of Rule 317, would in all cases result in either no difference in the 

source’s Rule 317 fee obligation or that it would increase the subject sources emissions 

and therefore decrease the emissions fee obligation. Therefore the use of the fixed 

Baseline (R), included in Rule 317, is a more conservative approach to establishing a 

Baseline, since it results in an equivalent or lower aggregate emissions Baseline and 

therefore a higher Rule 317 emissions fee obligation. 

Figure D. Summary of Alternative Baseline Comparison 

Annualized Baseline Alternative 

Aggregate

Emissions

(Tons)

R = Average of 2005-06 and 2006-07 emissions (Current Rule 317 

Baseline) 11,481

H = Highest Consecutive 2 Years in Last 10 Years 18,562

H-R = (Additional increase in Baseline emissions, resulting in a 

 reduction of Rule 317 fee obligation) 7,081

Figure E shows all possible 2-in-10 baseline combinations (aggregate emissions averaged over 

all two consecutive year combinations) as compared to the highest 2-in-10 baseline alternative.

The last column shows the difference in emissions when a source can choose the Baseline years 

over which to average in contrast to a fixed 2-in10 baseline. In all cases, for the 10-year span 

(2000-2010) considered in this analysis, it can be seen that the use of the highest 2-in-10 baseline 
D- 16 

always results in increased baseline emissions compared to a fixed 2-in-10 baseline and 

correspondingly in reduced fee obligation. 

Figure E – Effect of Alternative Averaged Consecutive Fixed Baseline Years 

2 Consecutive Years Averaged Fixed Baseline 

(tons) 

Highest 2-in-10 

(tons) 

Increased Baseline 

(tons) 

FY00-01/01-02 17,314 18,562 1,248 

FY01-02/02-03 13,728 18,562 4,834 

FY02-03/03-04 12,843 18,562 5,719 

FY03-04/04-05 12,431 18,562 6,131 

FY04-05/05-06 11,932 18,562 6,630 

FY05-06/06-07 11,481 18,562 7,081 

FY06-07/CY08 11,128 18,562 7,434 

CY08/CY09 10,500 18,562 8,062 

CY09/CY10 10,001 18,562 8,561 

Per your request, staff is including Figure F, which reflects a larger set of facility universe (234 

facilities subject to Rule 317) that is comprised of all facilities that reported actual emission 

greater than ten tons per year of either VOC or NOx for calendar year 2010, regardless whether 

they have a complete VOC and/or NOx emissions profile for the prior 10 years. Similar to 

Figure E, VOC and NOx emissions for each facility for the 10-year span are displayed in Figure 

F in an aggregate form. This data set of 234 facilities corroborates the year to year variability in 

emissions observed with the smaller facility universe that the variability analysis above was 

based on. 

The data for Figures B and F are from facilities that have actual emissions greater than 10 tons 

per year in CY 2010. The data is presented to highlight the variability in the emissions, and not 

to depict the actual universe of facilities subject to Rule 317. Staff estimates there are 

approximately 400 facilities in the Rule 317 universe. 
D- 17 

Figure F. Aggregate NOx and VOC Emissions Data (2000-2010) For All Sources with Actua

Tons (VOC or NOx) in CY2010

Facility CY2010 CY2009 CY2008 FY06-07 FY05-06 FY04-05 FY03-04 FY02-03 F1 12.7 - 12.8 15.9 15.8 13.6 - - F2 13.9 14.6 15.3 17.5 16.5 17.3 19.1 16.4 F3 33.4 32.6 34.9 30.1 33.4 32.3 31.7 25 F4 12.3 10.7 11.4 - 10.2 - - - F5 11.9 - - 21.4 19.1 16.3 22.3 20.7 F6 15.5 15 15.1 15.1 - - - - F7 30 25.7 49.6 57.3 67 72.7 50 44.2 F8 11.2 - - - - - - - F9 84.2 67.4 90 92.9 99.4 133.2 130.6 134.1 F10 48.2 27.3 33.9 - - - - - F11 20.7 22.9 21 39.7 52.2 88.2 87.2 81 F12 156.9 152.8 201.7 228.7 229.7 214.2 205.3 203.5 F13 35 30.9 27.7 44.2 48.2 74.9 55.3 30.1 F14 74.5 78.5 134.6 171.8 183 163.3 279.4 366.9 F15 11 20.3 38.3 34.8 47.1 41.7 41.7 - F16 78.8 97 97.9 91.1 77.3 84.5 115.7 98 F17 12.9 - - - - - - - F18 14.9 14.7 14.5 - - 16.2 16.5 - F19 64.6 71.5 72.7 64.1 66.8 62.9 74.8 143.2 F20 28.6 32.7 22.1 21 26.2 29.1 26.9 30.3 F21 36.3 32.7 47.4 60 75.9 82.8 84.1 55.7 F22 29.9 33.5 59.7 70.8 57.9 64.7 58.3 61.1 F23 42.3 37.7 41.7 41.6 34.8 48.4 60.1 61.7 F24 17.4 18.4 21 24.4 34.1 33.5 25 15.7 
D- 18 

Facility CY2010 CY2009 CY2008 FY06-07 FY05-06 FY04-05 FY03-04 FY02-03 F25 13.4 15.9 13.1 13.5 14 14.8 14.6 15.3 F26 16.7 - 13.1 13.1 - - - - F27 36.7 15.3 44 49.7 85.5 76.9 46.3 62.7 F28 12.3 - - - - - - 13.6 F29 16.8 - 14.7 18.1 20.9 20.2 19.4 19.1 F30 20.9 43.7 34.1 - - - - - F31 11.1 - 16.6 22.7 24.2 21.6 18.8 23.6 F32 22 16.7 22 52.2 52.4 63.8 56.7 45.1 F33 16.1 - 13.7 17 18 23.3 19.8 22.7 F34 33.1 - - - - - - - F35 29.7 25.6 29.2 22 - 19.8 30.5 - F36 30.5 28.2 25 21.5 19.2 16.4 14.7 18.3 F37 17.4 14.3 - 17.4 21.2 21.9 32.5 28.6 F38 11.7 - 10.9 13.5 17.6 17.4 16.8 14.4 F39 15.9 30.4 32.7 29.4 24.7 24.8 27.4 25.5 F40 17.5 15.2 13.5 19.5 22.5 27.1 23.1 28.6 F41 188 197.3 208.2 180.4 183.5 186.7 186.1 186.5 F42 34.3 35.1 28.9 36.8 17 16.9 16.4 22.9 F43 59.7 49.1 53.5 104 97.4 117.7 102 89.8 F44 14.8 13.4 14.3 24.9 25.3 40.3 28.7 30 F45 45.6 44.9 40.3 38 41.9 44.7 51.2 44.6 F46 44 41.4 40.4 53.5 48.5 55 61.6 64.6 F47 47.3 32.2 88.1 71.5 103.5 122.8 119.7 122.4 F48 57 63.4 71.1 89.9 87.4 111 95.2 91.5 F49 34.1 40.3 41.5 45.7 47.1 48.1 37.5 41.3 F50 32.8 34.7 30.4 40.3 39.3 37.2 34.6 75.2 F51 26.1 26.2 28.5 27.1 25 22.7 18.6 17.8 
D- 19 

Facility CY2010 CY2009 CY2008 FY06-07 FY05-06 FY04-05 FY03-04 FY02-03 F52 123.8 117 108.7 130.2 105.2 104 101.6 146.9 F53 20.4 20 24.8 20.4 16.9 25.8 24.9 20.5 F54 87.6 78.9 86.2 106.3 113.4 135.3 125.6 110.2 F55 14.3 16.4 17.5 21.5 25.3 34.7 51.6 37.3 F56 13.1 - - - - - - - F57 120.4 111.3 106.2 85.2 97.8 101.9 114 115.5 F58 50.5 51.2 66.8 63.5 67.8 54.8 65.4 53.6 F59 11.6 11.9 12.1 12.3 13.1 11.4 - 11.1 F60 15.9 29.1 13.3 16.5 - - - - F61 15.7 15.1 13.4 15.4 16.7 15.8 14.2 12.1 F62 20.8 19.4 20.6 27.1 29.5 26.1 18.3 25.3 F63 21.6 14.5 20.4 22.9 23.4 26 14.9 15.5 F64 20.8 19.7 22 25.1 24 25.5 30.1 33 F65 348.3 345.6 269.5 338.9 325.3 318.6 296.9 329.6 F66 15.9 16.3 16.6 15.9 15.3 18.8 20 18.7 F67 11.8 13.4 - 20.4 15.1 16.1 21.8 20 F68 186 114.8 147.3 164.9 185.4 150.8 189.5 177.9 F69 13 13.4 13 13.9 - - 12.7 14 F70 18.7 13.6 13.8 13.6 30.5 36.4 34.9 31.3 F71 32 31.9 30.5 28.4 27.1 18.9 17.2 21.9 F72 54.8 40 51.1 51.6 45.9 41.8 48.4 29.8 F73 43 32.6 35.6 56.1 50.9 39.5 30.6 26.5 F74 42.9 39.9 36.7 40.8 40.7 38.4 60.5 54 F75 99.9 121.7 141.1 121.8 126.4 128 111.8 125.1 F76 12.7 12.9 15.5 - 12.3 18.1 17.7 - F77 42 33.7 38.7 44.3 42.6 42.8 31.8 31.1 F78 14.7 15.6 19 20.7 16.9 16.9 17.2 12.1 
D- 20 

Facility CY2010 CY2009 CY2008 FY06-07 FY05-06 FY04-05 FY03-04 FY02-03 F79 19.4 - - - - - - - F80 88 122.8 58.3 - - - - - F81 49.7 50.1 42.1 33.1 31.9 22.5 17.3 18.8 F82 84 69.9 108.2 86.9 91.7 110.9 92.3 89.9 F83 19.6 19.6 19.6 19.5 12.8 19.8 19.9 21.2 F84 19.2 - - 15.6 - 14.5 - - F85 59.4 52.4 49.8 45.6 23.5 23.5 16.8 19.3 F86 12.5 19.5 30.3 35.6 28.6 26.2 27.3 29.2 F87 18.9 19.8 17.4 22.9 23.6 44.4 79.3 47.3 F88 15.7 - 12.6 16.8 17.2 16.2 20.5 19.2 F89 115.2 105.9 108.5 102 99.6 102.7 110.6 112.5 F90 10.5 10.7 11.2 11.1 11.1 10.9 10.8 11.3 F91 206 205.1 208 207.1 195.3 196.6 - - F92 64 77.3 53.8 49.4 56.1 65.9 55.4 60.5 F93 18.7 18.6 22.7 18.9 42.9 25.2 15 15 F94 17.5 20.6 21.2 26 20.9 18 16.9 15.8 F95 12.6 - - 12 13.1 13.5 16.3 18.8 F96 22.3 19.3 27.1 29 20.2 15.5 31 22.7 F97 43.2 38.4 35.7 32 34.4 39.8 33 28.2 F98 26.7 19.2 26.4 31.2 29.4 23.1 23.5 21.1 F99 47.3 56.4 49.9 46.6 47.4 65.1 - - F100 10.6 - 12.1 10.8 13.3 13 - - F101 13.2 14.2 15.4 11.1 10.8 13.3 - - F102 12.9 11.3 - 12 11.6 12.5 47.6 47.8 F103 15.7 15.3 14.6 16.5 14.8 17.4 17.9 19.1 F104 12.4 11.8 15.1 17.1 24.6 31.1 31.6 41.2 F105 10.1 - - - - - 50.4 83.9 
D- 21 

Facility CY2010 CY2009 CY2008 FY06-07 FY05-06 FY04-05 FY03-04 FY02-03 F106 11.2 - - - 14 24.5 - 12.5 F107 24.9 22.6 18.2 33.1 28 35.7 47.4 51.3 F108 27.6 20 29.3 32.2 30.3 - 15.1 - F109 22.3 33.6 32 42.8 29 45 - 65.2 F110 29.8 26.8 28.5 25.7 27.9 28.6 24.6 30.7 F111 37.5 44.7 47.4 47.4 45 51.7 54.1 51.7 F112 13.3 26.4 41.7 29 42.8 22.5 20 124.2 F113 38.4 43.2 54.6 40 47.4 62.8 74.3 66 F114 42.7 73.4 107.7 53.8 70.7 118.5 153.3 287.6 F115 14.5 38.6 19.8 50.3 40.7 39.8 41.6 57 F116 18.2 39.2 36.4 25.9 52.6 35.9 48.7 124.2 F117 17.1 18 20.1 22.4 27.4 26.6 29.4 43.6 F118 12.8 14 15.4 - - - 25.8 23.5 F119 11.1 11.6 11.1 - - - 15.2 14.4 F120 18.5 20.6 17.1 20 20.8 21.9 22.1 20.2 F121 42.2 31.4 39.7 22.6 24 - - - F122 91.2 96.8 123.9 83.4 100.5 127.8 58.3 54.3 F123 13.1 14.3 13.4 21.1 20.9 15.3 15 21.1 F124 15.4 15.7 14.4 17.3 17.2 16.7 25.1 43.6 F125 16.8 17 16.2 18.9 - 24.6 24.4 27.3 F126 10.6 25.7 26.9 28.3 21.2 12 - - F127 15.1 - - 17.1 15.1 15.1 14.5 - F128 134.3 142.1 149.1 154.3 137.6 137.8 149 153.5 F129 21.2 15.4 40.4 47.5 61.8 53.7 54.4 54.7 F130 161.6 154.7 175.5 177.1 109.4 - - - F131 21.6 27.5 25.5 24.5 26.9 41.9 42.9 65 F132 14.4 24.4 24.1 24.4 24.1 23.8 17 17.8 
D- 22 

Facility CY2010 CY2009 CY2008 FY06-07 FY05-06 FY04-05 FY03-04 FY02-03 F133 17.6 18.1 14.7 16.2 17.9 18.9 19.2 - F134 33.2 88 51.2 59.5 54.1 52.8 68.3 66.2 F135 24.2 27.8 38.9 41.5 47.1 55.4 33.8 47.5 F136 15.1 - - - - - - - F137 30.1 29.1 27.2 33.9 32.3 - 30 - F138 10.8 - 14.6 11.1 - 129.8 - - F139 46.5 45.3 45.3 43.8 35.3 - - - F140 34.9 36.1 35.3 34.2 30.1 23.1 26.9 29.5 F141 17 15 11.8 - - - 17.3 - F142 13.1 16.1 - - - - 14.1 - F143 99.8 48.3 31.8 - - - - - F144 1,130.10 1,195.90 1,224.90 1,166.80 1,285.30 1,637.30 1,212.10 1,135.40 F145 214.1 189.9 188.7 215 285.9 319.9 307 311.9 F146 10.5 10.3 10.7 - - - - - F147 14.4 16.2 17.9 32.1 20.6 - 14.6 - F148 16.4 19.8 24 20.8 21.9 - 18.3 34.8 F149 13 11.7 11.7 23 22.9 23 23.1 11 F150 44.9 32.5 - - - - - - F151 21.5 19.1 23.4 27.5 40.9 22.8 19.8 - F152 28.4 31 28.9 36.6 24.3 37.8 - - F153 28.7 28 32.1 - - - - - F154 23.8 24.5 24.8 14.4 - - - - F155 44.6 33.5 - - - - - - F156 10.8 10.2 10.2 10.2 - - - - F157 10.1 10.5 10.5 11.1 11.4 - - - F158 26.2 23.9 36.6 54.9 58.4 - - - F159 15.8 10.8 15 15 18.2 - - - 
D- 23 

Facility CY2010 CY2009 CY2008 FY06-07 FY05-06 FY04-05 FY03-04 FY02-03 F160 12.8 15.2 14.3 14.1 13.6 - - - F161 19.8 19.9 16.3 17.4 - - - - F162 16.2 16.2 16.2 15.7 14 - - - F163 15.2 20.2 25.1 25.6 25.8 - - - F164 10.3 11.4 13.8 17.2 17.3 - - - F165 12.9 12.9 12.1 - - - - - F166 15.5 13.7 13.7 13.3 - - - - F167 35 37.2 24.7 - - - - - F168 21.6 13.7 14.3 16.2 - - - - F169 15.8 17.8 - - - - - - F170 202.4 192.1 201.5 189.5 - - - - F171 88.9 92.6 104.5 120.4 - - - - F172 69.7 68.4 88.7 106.9 - - - - F173 27.2 26.8 23.2 - - - - - F174 16 32.7 12.8 - - - - - F175 19.1 24.5 35.3 - - - - - F176 13.2 - - - - - - - F177 11.4 32.3 46.1 - - - - - F178 24.5 28.3 - - - - - - F179 123 118.4 134.6 - - - - - F180 18 15.9 21.1 - - - - - F181 19.9 - - - - - - - F182 11.2 - - - - - - - F183 18.9 20.2 17.5 19.3 21.5 15.4 20.7 23.9 F184 385.7 373.4 361.7 470.6 375.1 404.7 390.2 441.7 F185 1,189.90 1,209.70 1,478.80 1,485.80 1,637.60 1,862.50 2,046.80 1,859.90 F186 17.2 14.9 - - - - - - 
D- 24 

Facility CY2010 CY2009 CY2008 FY06-07 FY05-06 FY04-05 FY03-04 FY02-03 F187 25.9 31 29.2 28.5 37.8 45.8 56 61.8 F188 18.7 19 16.4 18.8 16.8 16.3 - - F189 33.5 24.9 23.6 43 41.9 45.4 46.3 34.7 F190 90.2 74.8 90.7 91.8 112.7 128.2 159.9 178.2 F191 145.6 155.1 160 123.8 133 176.4 217.5 335.4 F192 87 91.8 79.6 76.1 68.9 78 144.9 110.5 F193 37.3 48.6 54.3 36 33.7 29.3 25.7 30.8 F194 1,365.90 1,321.50 1,387.80 1,401.70 1,446.10 1,488.30 1,424.20 1,468.30 F195 15.2 16 14.1 12.2 - 13.4 15.7 19.4 F196 21.2 16.4 23 26.6 24 27.3 28 27.1 F197 251.8 251.6 296.7 291.7 216.3 279.4 264.8 221.5 F198 89.4 97.5 91.8 102.2 82.9 80.2 - - F199 17.5 17.3 18.2 - - 28.3 27.1 44.3 F200 24.2 18.4 42.4 30.5 26.1 47.8 91.8 56.5 F201 57.9 59.2 56.1 66.5 43.9 38.3 37.1 37 F202 161.9 182 191.9 245.2 233.1 216.7 183 223.6 F203 30.4 25.6 24.3 41.7 56.7 47 55.5 54.2 F204 51.3 75.2 85 87.2 80.5 83.7 72.6 22 F205 35.8 57.9 20.7 42.2 64.4 109.4 63.1 28.9 F206 20.7 26.4 22.9 22.1 21.9 18.4 - 15.9 F207 42.3 26.6 24.9 27.4 25.6 24 20.8 21.8 F208 43.9 49.5 46.9 47.6 49.7 49.8 38.9 42.7 F209 117.4 108.8 105.2 113.3 117.7 129.1 106.8 126.5 F210 183.2 176.5 145.7 132.9 165 138.6 176.9 241.6 F211 144.2 138.9 138.1 141.3 132.9 128 123.9 124.8 F212 29.9 57 51.8 89.9 81.2 83.6 79.3 59.2 F213 18.4 18.4 19 17.1 17.6 14.2 15.2 14.4 
D- 25 

Facility CY2010 CY2009 CY2008 FY06-07 FY05-06 FY04-05 FY03-04 FY02-03 F214 13.2 13 14 15.4 14.8 13.4 15.9 13.3 F215 14.6 14.4 14.5 17.2 28.1 44.4 51.2 - F216 51.5 52.8 49.7 41.5 40.3 37 46.8 53.4 F217 14.2 14.2 17 17.6 18.7 17.6 19.1 21.6 F218 17.2 16.6 15 15.9 15.4 16.5 18.5 21 F219 16.1 15.8 13.7 15.3 12.3 14.9 14.5 14.8 F220 18.3 13.5 - 16 14.2 - - - F221 49.8 48.9 50 46.8 57.7 56.5 54.3 62.4 F222 43.2 43.9 53.8 57.4 48.3 62.3 76.9 72.5 F223 50.8 56.1 53.5 52.1 55.3 52.5 54.5 75.9 F224 431.3 451.4 441.2 465.1 518.9 496.1 546.5 505 F225 798.9 894.7 968.4 913.7 886 825 918 889.7 F226 25.2 23.4 21.4 23.2 21.7 24.8 23.9 23.6 F227 11.4 11.3 11.4 - - - 25.4 25.5 F228 129.3 125.7 149.2 143.3 132.7 131.7 126.1 128.5 F229 36.2 35.5 38.8 - - - 16.5 - F230 20.7 - 27.6 33.9 31.9 31.6 44.5 46.2 F231 14 21.4 19.8 20 20.2 19.3 19.3 19.8 F232 14.5 - 22.3 - 19.2 - - - F233 11.6 - 12.6 - 16.8 19.5 14.6 - F234 924.9 919.6 1,095.60 1,076.00 - - - - 

- = no reported emissions