San Joaquin Valley Unified Air Pollution Control District September 18, 2014

Supplemental Document: Subpart 4 Requirements

2012 PM2.5 Plan and Rule 2201

Supplemental 

Document

Clean Air Act 

Subpart 4:

The 2012 PM2.5 Plan

for the 2006 PM2.5 

Standard and District 

Rule 2201 (New and 

Modified Stationary 

Source Review)

2012 PM2.5 Plan and Rule 2201

SJVUAPCD
San Joaquin Valley Unified Air Pollution Control District September 18, 2014

Supplemental Document: Subpart 4 Requirements

2012 PM2.5 Plan and Rule 2201

This page intentionally blank.
San Joaquin Valley Unified Air Pollution Control District September 18, 2014

1 Supplemental Documentation: Subpart 4 Requirements

2012 PM2.5 Plan and Rule 2201

Supplemental Document: Clean Air Act Subpart 4 Requirements

This document demonstrates that the San Joaquin Valley Unified Air Pollution Control 

District’s (District) adopted 2012 PM2.5 Plan1satisfies federal PM2.5 plan requirements 

under subpart 4 of Part D of Title I of the Clean Air Act (CAA) (referenced herein as 

subpart 4). Additionally, this supplemental document also demonstrates that Valley 

attainment of the 2006 PM2.5 standard by 2015 is not practicable. As such, the District 

requests the U.S. Environmental Protection Agency (EPA) approve the already 

submitted 2012 PM2.5 Plan and reclassify the San Joaquin Valley air basin (Valley) as 

a serious nonattainment area. Finally, this document demonstrates that the District’s 

most recently adopted Rule 2201, New and Modified Stationary Source Review2

(adopted April 21, 2011) fully satisfies the requirements of subpart 4.

1 BACKGROUND

The District adopted its 2012 PM2.5 Plan on December 20, 2012 to satisfy requirements 

from EPA’s 2007 Fine Particle Implementation Rule3, which was grounded in subpart 1 

of the CAA. However, weeks later, in January 2013, the D.C. Circuit Court4found that 

EPA erred in implementing federal PM2.5 standards pursuant solely to the general 

implementation provisions of CAA subpart 1 of Part D of Title I without also considering 

the particulate matter-specific provisions of subpart 4 of Part D (subpart 4). As a result, 

on June 2, 2014, EPA classified the Valley (and all other PM2.5 nonattainment areas) 

as “moderate” under subpart 4.5 EPA must evaluate the District’s 2012 PM2.5 Plan

under subpart 4 for the CAA, per the court ruling. 

CAA subpart 1 provides general guidance for nonattainment areas, while CAA subpart 4 

provides additional provisions for particulate matter nonattainment areas. The following 

is a comparison of requirements air districts must comply with pursuant to subpart 4 

requirements versus analogous requirements in subpart 1. Requirements specific to 

subpart 1 that have no analogous requirement in subpart 4 will not be included in this 

summary because this supplemental document is specific to subpart 4 requirements. 

While subpart 4 requirements are specific to PM10, the court has ruled that subpart 4 

applies equally to PM2.5, and so the references below refer to PM2.5, the subject of this 

document.

 

 

1

SJVUAPCD. 2012 PM2.5 Plan. Retrieved on 5/5/14 from 

http://www.valleyair.org/Air_Quality_Plans/PM25Plans2012.htm

2

SJVAPCD. Rule 2201 (New and Modified Stationary Source Review Rule). Retrieved on 7/15/2014 from 

http://www.valleyair.org/Board_meetings/GB/agenda_minutes/Agenda/2011/April/Agenda_Item_8_Apr_21_2011.pdf. 

3

EPA. 40 CFR Part 51. Clean Air Fine Particle Implementation Rule; Final Rule. (20586 – 20667) April 25, 2007. 

Retrieved on 5/5/14 from http://www.epa.gov/fedrgstr/EPA-AIR/2007/April/Day-25/a6347.pdf. 

4 Natural Res. Def. Council v. E.P.A., 706 F.3d 428, 430 (D.C. Cir. 2013)

5

EPA. 79 Fed. Reg. 105, pp. 31566-31782. Identification of Nonattainment Classification and Deadlines for 

Submission of State Implementation Plan Provisions for the 1997 Fine Particle (PM2.5) National Ambient Air Quality 

Standard (NAAQS) and 2006 PM2.5 NAAQS, codified at 40 CFR Chapter 1. Retrieved 7/21/2014 from 

http://www.gpo.gov/fdsys/pkg/FR-2014-06-02/pdf/2014-10395.pdf. 
San Joaquin Valley Unified Air Pollution Control District September 18, 2014

2 Supplemental Documentation: Subpart 4 Requirements

2012 PM2.5 Plan and Rule 2201

Classification and Reclassification 

 Subpart 1: EPA may classify nonattainment areas, but is not required to (CAA 

§172(a)(1)).

 Subpart 4: All areas designated nonattainment for PM2.5 are classified as 

Moderate nonattainment by order of law (CAA §188(a)). 

o Moderate nonattainment areas can be reclassified to Serious nonattainment 

(CAA §188(b)) under the following conditions: 

 If the area shows it cannot reasonably attain the standard by the deadline 

associated with the Moderate nonattainment classification, it can be 

reclassified before the attainment date. 

 If a Moderate nonattainment area fails to attain the standard by the 

Moderate nonattainment attainment date, then the area shall be 

reclassified as Serious nonattainment. 

Attainment Dates

 Subpart 1: Five years from the date of designation (CAA §172(a)(2)).

o The attainment date may be extended up to 10 years from date of designation 

and (2) 1-year extensions may be issued.

 Subpart 4: (CAA §188(d & e))

o Moderate nonattainment areas have an attainment deadline of the end of the 

sixth calendar year after designation.

 Up to two 1-year extensions are available to each Moderate 

nonattainment area without reclassification to Serious nonattainment. 

o Serious nonattainment areas have an attainment deadline of the end of the 

tenth calendar year after designation.

 One extension of up to five years is available if the attainment deadline is 

unfeasible and the state complies with all requirements and commitments, 

and the state implementation plan (SIP) includes the most stringent 

measures practicable. 

Plan Submissions Deadlines 

 Subpart 1: Plans due three years after designation

 Subpart 4:

o Moderate nonattainment areas must submit a plan within 18 months after 

nonattainment designation.

o Serious nonattainment areas must submit a plan containing best available 

control measures at 18 months and a full attainment plan no later than four 

years after reclassification to Serious; however, areas reclassified under CAA 

§188(b)(2) must submit the attainment demonstration within 18 months after 

reclassification to Serious.

 If an area fails to attain, that area must submit SIP revisions to EPA within 

12 months of the failed attainment date that demonstrates attainment and 

an annual 5% reduction of PM2.5 or PM2.5 precursors.
San Joaquin Valley Unified Air Pollution Control District September 18, 2014

3 Supplemental Documentation: Subpart 4 Requirements

2012 PM2.5 Plan and Rule 2201

Level of Emissions Controls 

 Subpart 1: Reasonably Available Control Measures (RACM) must be 

implemented as soon as practical

 Subpart 4:

o Moderate nonattainment areas must implement RACM within 4 years of 

designation.

o Serious nonattainment areas must implement Best Available Control 

Measures (BACM) within 4 years after the area is classified as Serious 

nonattainment. 

o EPA will issue RACM and BACM guidance for urban fugitive dust, residential 

wood combustion, and prescribed silviculture and agriculture burning (CAA 

§190)

Precursor Requirement Presumptions and RACM

 Subpart 1: Areas are not required to address sources of ammonia and VOCs, 

unless it is technically demonstrated that ammonia or VOC significantly 

contributes to PM2.5 concentrations in the area (EPA Implementation Rule).

 Subpart 4: Areas must address sources of ammonia and VOCs for RACT and 

other areas of the plan, unless the state demonstrates that such sources do not 

significantly contribute to PM2.5 exceedances in the area (CAA §189(e)).

Permitting program

 Subpart 1: 

o An area needs a permitting program that meets CAA §173 for PM10 new and 

modified major stationary sources. 

o An area is not required to address sources of ammonia and VOCs, unless 

EPA or the state technically demonstrates that ammonia or VOC significantly 

contributes to PM2.5 concentrations in the area (EPA Implementation Rule).

 Subpart 4: 

o A Moderate nonattainment area needs a permitting program that meets CAA 

§173 (in Subpart 1) for new and modified major PM2.5 stationary sources 

(CAA §189(a)(1)(A)). 

o A Serious nonattainment area must change the definition of Major Sources to 

include a stationary source or any group of stationary sources with a potential 

to emit of at least 70 tons per year of PM2.5 (CAA §189(b)(3)).

o Major stationary sources must address precursors of PM2.5, unless the state 

demonstrates that such sources do not significantly contribute to levels that 

exceed the standard (CAA §189(e)).

Available Waivers 

 Subpart 1: No analogous waivers are available in Subpart 1 as allowed in 

Subpart 4. 

 Subpart 4: 

o No available waivers for a Moderate nonattainment area. 

o For a Serious nonattainment area, EPA may waive any Subpart 4 

requirement (including a specific date for the attainment deadline) if 
San Joaquin Valley Unified Air Pollution Control District September 18, 2014

4 Supplemental Documentation: Subpart 4 Requirements

2012 PM2.5 Plan and Rule 2201

anthropogenic PM2.5 sources do not contribute significantly to PM2.5

violations. (CAA §188(f)).

This supplemental document addresses the five aspects of PM2.5 implementation 

where of Subpart 4 differs from Subpart 1 for the Valley: 

1. Attainment Date 

2. Reasonably Available Control Measures

3. Reasonable Further Progress

4. Contingency Measures

5. New Source Review Program

2 ATTAINMENT DATE

Pursuant to subpart 4 Section 188(c)(1), the attainment date for a moderate area shall 

be as expeditiously as practicable but no later than the end of the sixth calendar year 

after the area’s designation, unless EPA determines that the moderate area cannot 

practicably attain the NAAQS by the attainment date and reclassifies the area as a 

serious nonattainment area (serious area). For a serious area, the attainment date shall 

be as expeditiously as practicable, but no later than the end of the tenth calendar year 

after designation.

The Valley was designated nonattainment for the 2006 PM2.5 standard in 20096; 

therefore, the attainment date for the Valley as a moderate area is 2015. The following 

discussion will substantiate that the District assessed the feasibility of attainment by 

2015 in the 2012 PM2.5 Plan and determined attainment by this date is not practicable 

and as such demonstrates the necessity of EPA to reclassify the Valley as a serious 

area. 

2.1 Valley Attainment of the 2006 Standard by 2015 Is Not Practicable

The 2012 PM2.5 Plan addresses the 2015 attainment date in Chapter 9 as a part of the 

analysis to determine the most expeditious timeline in which the Valley can attain the 

standard. The analysis confirms that attainment of the 2006 standard by 2015 is not 

practicable. 

Photochemical modeling and other technical analyses establish an emissions level at 

which the Valley would attain the federal 24-hour PM2.5 standard. Given the significant 

contribution of ammonium nitrate to the Valley’s PM2.5 concentrations, reductions in 

NOx emissions are particularly important. To achieve the NOx reductions critical for 

reaching attainment in the Valley, ARB has adopted regulations that will significantly 

reduce NOx emissions from various mobile sources. Achieving this level of emissions 

reductions requires adequate time and carries a tremendous cost. These reductions 

 

6

EPA. 40 CFR Part 81. Air Quality Designations for the 2006 24-Hour Fine Particle National Ambient Air Quality 

Standards. (58688-58781) November 13,2009. Retrieved on 5/5/14 from http://www.gpo.gov/fdsys/pkg/FR-2009-11-

13/pdf/E9-25711.pdf. 
San Joaquin Valley Unified Air Pollution Control District September 18, 2014

5 Supplemental Documentation: Subpart 4 Requirements

2012 PM2.5 Plan and Rule 2201

are ultimately achieved in time to bring most of the Valley into attainment well before 

2019, with the exception of Bakersfield. 

All areas of the Valley will attain the standard in 2019 with the regulatory controls in the 

2012 PM2.5 Plan. Kern County is projected to be the last portion of the Valley to attain, 

and is thus the area with the most need for additional emissions reductions through the 

2012 PM2.5 Plan. In order for Bakersfield to attain by 2015, an additional 11.8 tons per 

day (tpd) of NOx reductions (as well as an additional 0.4 tpd of PM2.5 reductions) would 

be needed in Kern County by 2015 (see Table 1). To put this in perspective, achieving 

this level of emissions reductions is equivalent to virtually eliminating all passenger 

vehicles AND 75% of stationary source NOx emissions in Kern County next year 

(2015). 

The District’s “no stone unturned” evaluation of emissions sources and emissions 

controls did not reveal any additional reasonably available emissions reductions 

opportunities that provide for attainment in 2015. All new control strategies are 

scheduled for implementation by 2017. The District intends to amend Rule 4692 

(Commercial Charbroiling) in 2016 with implementation in 2017. Rule development 

cannot be expedited for this measure because time is needed for continued research 

and technology demonstration projects, which the District is actively facilitating7. The 

District also committed in the 2012 PM2.5 Plan to amend Rule 4901 (Wood Burning 

Fireplaces and Wood Burning Heaters) in 2016. District Rule 4901 is already amongst 

the most stringent rules for this source category, and expediting this rule alone would 

not be enough to accelerate attainment. That said, the District is working to amend this 

rule early, with implementation in 2014. 

Thus, the 2012 PM2.5 Plan’s 2019 attainment year demonstration also illustrates that 

attainment by 2015 is not practicable, supporting a request for reclassification to 

serious. 

 

7

See the District’s Restaurant Charbroiler Technology Partnership program: 

http://www.valleyair.org/grants/content/rctp.html
San Joaquin Valley Unified Air Pollution Control District September 18, 2014

6 Supplemental Documentation: Subpart 4 Requirements

2012 PM2.5 Plan and Rule 2201

Table 1 Kern County Attainment Outlook (tons per day) 

Ref#

2007 

base 

year

2015 2016 2017 2018 2019

1

Winter PM2.5 emissions 

inventory, reflecting adopted 

control measures 

15.4 11.5 11.4 11.4 11.4 11.4

2

New control measure 

commitments 0 0.1 0.3 0.3 0.3

3

Winter PM2.5 emissions 

inventory reflecting full 

plan control strategy (Line 

1 – Line 2 above)

11.5 11.3 11.1 11.1 11.1

4 Direct PM2.5 Attainment Target 11.1

5

Winter NOx emissions 

inventory, reflecting full plan 

control strategy 

115.4 58.6 54.5 51.5 48.9 46.8

6 NOx Attainment Target 46.8

7

Winter SOx emissions 

inventory, reflecting full plan 

control strategy 

3.6 1.8 1.8 1.8 1.8 1.8

8 SOx Attainment Target 1.8

Attainment? No No No No Yes

Projected attainment year 2019

2.2 Reclassification from Moderate Area to Serious Area 

Pursuant to subpart 4 Section 188(b) a moderate area may be reclassified for one of the 

following two circumstances: 

1. Before the Attainment Date: Any moderate area that EPA determines cannot 

practicably attain the NAAQS by the attainment date. 

2. Upon Failure to Attain: Any moderate area that EPA finds is not in attainment 

after the applicable attainment date shall be reclassified by operation of law as a 

serious area. 

As discussed above, attainment by the moderate deadline of 2015 is not practicable, so 

the Valley should be reclassified as a serious nonattainment area. For a serious area, 

the attainment date shall be as expeditiously as practicable but no later than the end of 

the tenth calendar year; therefore, should the Valley be redesignated as a serious area, 

the latest attainment deadline would be 2019. The District would demonstrate an 
San Joaquin Valley Unified Air Pollution Control District September 18, 2014

7 Supplemental Documentation: Subpart 4 Requirements

2012 PM2.5 Plan and Rule 2201

appropriate attainment year in a new attainment plan satisfying serious area 

requirements upon EPA reclassification to serious. 

3 REASONABLY AVAILABLE CONTROL MEASURES (RACM)

3.1 Subpart 4 requirements for RACM 

Subpart 4 Section 189(a)(1)(C) states that moderate area SIPs must demonstrate that 

reasonably available control measures (RACM) must be in place within four years of its 

nonattainment designation. Areas classified serious must implement best available 

control measures (BACM) (Section 189(b)(1)(B), but as the Valley is currently classified 

as moderate, BACM will be addressed in a future plan. The subpart 4 RACM 

requirement is satisfied by section 9.2 of the 2012 PM2.5 Plan, and is summarized 

below.

For a plan demonstrating the impracticability of attainment by the moderate area 

deadline, “EPA believes it is reasonable for all available control measures that are 

technologically and economically feasible to be adopted for areas that do not 

demonstrate attainment. ... EPA anticipates that any future implementation of BACM for 

these sources will be additive to, and hence compatible with, RACM.”8

RACM are, by definition, reasonable. Although an air quality attainment plan must 

include a thorough analysis of reasonably available measures, it need not analyze every 

conceivable measure; reasonability must drive the analysis. Any measure that is 

absurd, unenforceable, impractical, or would cause severely disruptive socioeconomic 

impacts is unreasonable. This analysis must consider all agencies’ opportunities 

together, but the starting point is the separate analyses of each agency.

As discussed in Section 2.0 above, the District is adopting reasonably available control 

measures as expeditiously as practicable. Furthermore, most of the nation’s most 

stringent controls are already in place in the Valley. This is demonstrated in great detail 

in Chapter 5 and Appendices C and D of the District’s 2012 PM2.5 Plan, and 

summarized below. There are no reasonable regulatory control measures excluded 

from use in the plan; therefore, there are no emissions reductions associated with 

unused regulatory control measures. 

3.2 NOx and PM

Although NOx and directly emitted PM2.5 emissions are key to attaining the NAAQS 

and commitments were made to amend NOx and PM2.5 specific rules in the plan, 

adopting amendments to these rules earlier than committed to in the 2012 PM2.5 Plan 

will not get the District into attainment before the 2015 deadline assigned to moderate 

areas. 

 

8 General Preamble to the CAA, 57 FR 13544.
San Joaquin Valley Unified Air Pollution Control District September 18, 2014

8 Supplemental Documentation: Subpart 4 Requirements

2012 PM2.5 Plan and Rule 2201

Specifically, the 2012 PM2.5 Plan committed to amend District Rules 4901 (Wood 

Burning Fireplaces and Wood Burning Heaters) and Rule 4692 (Commercial 

Charbroiling), both in 2016. The District’s Board directed staff to amend Rule 4901 in 

2014 based on the District’s Health Risk Reduction philosophy. Rule 4901 is in the 

process of undergoing the public amendment process this year and is expected to be 

taken to the Governing Board for public hearing in the third quarter of 2014, with a plan 

emission reductions commitment of at least 1.5 tpd of PM2.5. However, the federallyenforceable commitment for Rule 4901 remains as implementation in 2016. While early 

adoption of Rule 4901 amendments will provide important public health benefits, it 

would not accelerate PM2.5 attainment since time is needed to fully implement the 

adopted mobile source regulations that achieve critical NOx emissions reductions for 

2019 attainment. 

Rule 4692 is scheduled for amendment in 2016 because the technology has not been 

proven feasible to require yet. The SCAQMD and District have been working together 

to demonstrate potential technologies in a controlled setting and are now moving 

forward to demonstrate control technologies in real-world settings in Valley restaurants. 

The 2016 timeline will allow for technologies to be proven feasible and to become 

commercially available. The amendments to this rule will reduce emissions by 0.4 tpd 

of PM2.5.
San Joaquin Valley Unified Air Pollution Control District September 18, 2014

9 Supplemental Documentation: Subpart 4 Requirements

2012 PM2.5 Plan and Rule 2201

3.3 Ammonia 

3.3.1 Ammonia Contribution to PM2.5 Concentrations 

The switch from CAA subpart 1 to subpart 4 for PM2.5 implementation shifts the 

precursor presumption for planning purposes. Under EPA’s original PM2.5 

implementation rule (based on CAA subpart 1), regions were not required to address 

ammonia unless technical demonstration shows that ammonia reductions contribute to 

PM2.5 attainment. Now, under subpart 4, regions are required to address ammonia as 

a precursor unless EPA determines that ammonia sources do not contribute 

significantly to PM concentrations. The starting presumption has thus changed, but 

scientific evaluation can still override that presumption. In the Valley, there is extensive 

scientific research and technical analysis demonstrating that ammonia reductions do not 

contribute to PM2.5 attainment. As such, the Valley’s ammonia emissions do not need 

to be reduced to address EPA’s PM2.5 standard.

The role of ammonia in the Valley’s PM2.5 concentrations is discussed in detail in 

Chapter 4 of the 2012 PM2.5 Plan, and is summarized here. Early air quality research 

in the Valley identified ammonium nitrate (nitrate) as a predominant secondary PM2.5 

species in the region, with high concentrations forming during the winter months.9 

Studies have continued to show that ammonium nitrate is a primary component of 

wintertime PM2.5 in the Valley, followed by other species, such as organic carbon, 

ammonium sulfate, and geologic material.10 In addition, PM2.5 speciation data, 

collected for many years at four Valley urban monitoring locations, also shows nitrate’s 

substantial contribution to the Valley’s total PM2.5 concentrations, especially on days 

when the 24-hour average concentration exceeds the 35 μg/m324-hour PM2.5 

standard.

Nitrate buildup is a signature outcome of multi-day stagnation periods during the winter 

(similar buildup is not observed during warmer seasons). The modeled regional 

variation of nitrate concentrations is shown in Figure 4-2 of the 2012 PM2.5 Plan. 

Higher concentrations of nitrate occur in the southernmost Valley as a result of slower 

wind speeds and higher levels of reactive nitrogen and ammonia.

Both nitric acid and ammonia are needed to form ammonium nitrate. The extensive 

research conducted through CRPAQS and subsequent studies, as well as ongoing 

evaluation and modeling demonstrates that there is a relative abundance of ammonia 

(NH3) compared to nitric acid (HNO3), and that the amount of nitric acid (resulting from 

NOx emissions) drives the ultimate formation of ammonium nitrate. Figure 4-3 of the 

2012 PM2.5 Plan illustrates this ammonia abundance at the rural Angiola (Fresno 

County) air monitoring site in the Valley during the CRPAQS field study. Ammonia 

 

9

Smith, T.B.; Lehrman, D.E.; Reible, D.D.; and Shair, F.H. (1981). The origin and fate of airborne pollutants within 

the San Joaquin Valley: Extended summary and special analysis topics. Report No. 2. Prepared for the California Air 

Resources Board, and by the California Institute of Technology, Pasadena, CA.

10 Ying, Q. & Kleeman, M.J., (2009). Regional Contributions to Airborne Particulate Matter in Central California during 

a Severe Pollution Episode. Atmospheric Environment, 43, 1218–1228.
San Joaquin Valley Unified Air Pollution Control District September 18, 2014

10 Supplemental Documentation: Subpart 4 Requirements

2012 PM2.5 Plan and Rule 2201

concentrations are considerably higher than nitric acid concentrations throughout the 

Valley, including urban areas with concentrated NOx emissions.11 

Because of the regional surplus in ammonia, even substantial ammonia emissions 

reductions yield a relatively small reduction in nitrate. Figures 4-4 and 4-5 of the 2012 

PM2.5 Plan provide a simplified illustration of this situation. As seen in Figure 4-6 of the 

2012 PM2.5 Plan, a comparable modeling analysis based on CRPAQS observational 

data found a higher disparity between the efficiency of NOx versus ammonia controls. 

Reductions in nitrate concentrations of 30% to 50% were realized through a 50% 

reduction in NOx, while a 50% reduction in ammonia only realized less than 5% 

reductions in nitrate concentrations. Finally, Figure 4-7 of the 2012 PM2.5 Plan

provides clear correlative evidence from observed data that NOx controls are effectively 

reducing ammonium nitrate, despite an increase in the regional ammonia inventory over 

the same time period.

Due to this extensive body of science that clearly shows the much greater efficacy of 

reducing NOx emissions relative to ammonia, ammonia reductions have not historically 

been considered a significant precursor to PM2.5 formation in the Valley. However, the 

District and ARB have continued to examine the potential role of ammonia with regard 

to PM2.5 formation (see Appendices F and G of the 2012 PM2.5 Plan).

The modeling sensitivity analysis conducted for the 2012 PM2.5 Plan shows that 

reductions in ammonia emissions achieve insignificant reductions in the 2019 PM2.5 

design values compared to reductions of direct PM2.5 and NOx emissions. As 

Appendix G of the 2012 PM2.5 Plan details:

 A 1 ton reduction in the Valley’s total direct PM2.5 emissions reduces the 

Bakersfield-California PM2.5 design value by 0.34 μg/m3

 A 1 ton reduction in the Valley’s total NOx emissions reduces the BakersfieldCalifornia PM2.5 design value by a 0.08 μg/m3

 A 1 ton reduction in in the Valley’s total ammonia emissions reduces the 

Bakersfield-California PM2.5 design value by a mere 0.008 μg/m3 

Relative to the other pollutants, ammonia emission reductions at the BakersfieldCalifornia site are only 2.3% as effective as directly emitted PM2.5 emission reductions, 

and only 10% as effective as NOx emission reductions. 

Furthermore, it would take an unreasonable tonnage of ammonia reductions to reduce a 

significant amount of PM2.5 mass. Since, as noted above, 1 ton of reduction in 

ammonia achieves a 0.008 μg/m3reduction in the PM2.5 design value, it would take a 

total ammonia reduction of 125 tons per day for the Valley to achieve only a 1 μg/m3

reduction in the PM2.5 design value. Based on the total ammonia emissions inventory 

for the Valley in the year 2019, this would equate to a 34% reduction of the total 

tonnage. Thus, current technical analyses demonstrate that ammonia reductions would 

 

11 Magliano, K. L. (2009) Science-Based Policies for Particulate Matter Air Quality Management in California. 

International Aerosol Modeling Algorithms Conference. Davis CA.
San Joaquin Valley Unified Air Pollution Control District September 18, 2014

11 Supplemental Documentation: Subpart 4 Requirements

2012 PM2.5 Plan and Rule 2201

not significantly contribute to the Valley’s attainment of the 2006 PM2.5 standard, so 

sources of ammonia emissions were not evaluated under the 2012 PM2.5 Plan.

12

 

Based on 2018 emissions and analysis, as discussed in the 2012 PM2.5 Plan, the 

District estimates the 2018 design value for Bakersfield-California is at least 1 μg/m3 

higher than the attainment level. It would take at least 125 tons of additional ammonia 

emissions reductions to advance attainment by one year. As discussed in Chapter 5 of 

the 2012 PM2.5 Plan, this is an infeasible amount of emissions reductions for ammonia. 

Nationwide, as regions continue to look into the issue of ammonia as a PM2.5 

precursor, research should continue to assess the relationship between ammonia 

emissions and ambient PM2.5 emissions. Ammonia control measures should only be 

required if additional ammonia reductions are found to be needed to meet health-based 

air quality standards.

3.3.2 Ammonia Controls

As noted in section 3.3.1, under subpart 4, regions are required to address ammonia as 

a precursor in RACT analyses and other areas of the plan unless EPA determines that 

ammonia sources do not contribute significantly to PM concentrations. To improve 

public health while also ensuring effective use of resources, additional ammonia 

controls should only be required when there is clear scientific evidence that reasonable 

measures to reduce ammonia emissions would be effective in significantly reducing 

ambient PM2.5 concentrations.

Extensive scientific research and technical analysis described above (and more 

extensively in the 2012 PM2.5 Plan) demonstrates that ammonia reductions do not 

contribute to the Valley’s PM2.5 attainment. That said, this section shows that the 

Valley’s ammonia emissions have been significantly reduced through stringent District 

regulations. This section also shows that additional ammonia reductions are infeasible. 

Because the science indicates that ammonia reductions do not contribute to the Valley’s 

PM2.5 attainment, and because additional ammonia controls are infeasible, the Valley’s 

ammonia emissions do not need to be further reduced to address EPA’s PM2.5 

standard. 

As demonstrated in Appendix B of the 2012 PM2.5 Plan, the three main sources of 

ammonia emissions in the Valley from stationary and area sources account for 96% of 

the Valley’s ammonia emissions and are as follows (based on 2015 estimates):

 Farming Operations with 239.2 tons per day (tpd), 

 Solvent evaporation from Agricultural Fertilizers at 66.1 tpd, and 

 Composting Solid Waste Operations at 20.5 tpd.

 

12 Clean Air Fine Particle Implementation Rule [PM2.5 Implementation Rule]. 72 Fed. Reg. 79, pp. 20586–20667 at p. 

20590 (2007, April 25). Retrieved from http://www.gpo.gov/fdsys/pkg/FR-2007-04-25/pdf/E7-6347.pdf#page=1
San Joaquin Valley Unified Air Pollution Control District September 18, 2014

12 Supplemental Documentation: Subpart 4 Requirements

2012 PM2.5 Plan and Rule 2201

Attachment A of this document presents a detailed evaluation of:

 Confined Animal Facilities (District Rule 4570)

 Agricultural Fertilizers

 Organic Material Composting (District Rule 4566)

 Biosolids, Animal Manure, and Poultry Litter Operations (District Rule 4565)

 Major Sources of Ammonia

Based on this analysis and the analysis summarized in section 3.3.1, there are no 

additional ammonia controls the District could adopt that would advance PM2.5 

attainment.

3.4 VOCs

3.4.1 VOC Contribution to PM2.5 Concentrations 

As discussed in the ammonia section above, the switch from CAA subpart 1 to subpart 

4 for PM2.5 implementation shifts the precursor presumption for planning purposes. 

Under EPA’s original PM2.5 implementation rule (based on CAA subpart 1), regions 

were not required to address VOCs unless technical demonstration shows that 

ammonia reductions contribute to PM2.5 attainment. Now, under subpart 4, regions are 

required to address VOCs as a precursor unless EPA determines that VOC sources do 

not contribute significantly to PM concentrations. The starting presumption has thus 

changed, but scientific evaluation can still override that presumption. In the Valley, 

there is extensive scientific research and technical analysis demonstrating that VOC 

reductions do not contribute to PM2.5 attainment. As such, the Valley’s VOC emissions 

do not need to be reduced to address EPA’s PM2.5 standard.

The role of VOCs in the Valley’s PM2.5 concentrations is discussed in detail in Chapter 

4 and Appendix F (Modeling Protocol) of the 2012 PM2.5 Plan, and is summarized 

here. 

As noted in Appendix F13, to evaluate the significance and effectiveness of VOC 

controls, isopleths of PM2.5 nitrate response generated with the CIT-UCD model of the 

January 4-6, 2006 IMS-95 episode accounted for both NOx and VOC emission 

reductions14. This modeling showed that NOx controls are the most effective approach 

to reduce PM2.5 nitrate concentrations, and once NOx controls are taken into 

consideration, VOC emission reductions produce essentially no benefit. In fact, in some 

instances, VOC emissions reductions may actually lead to an increase in PM2.5 nitrate 

formation. Nitrogen-containing molecules such as PAN can act as temporary sinks for 

NO2. When VOCs are controlled, the reduced availability of certain radicals which are 

 

13 2012 PM2.5 Plan Appendix F (Modeling Protocol), p 32. http://www.valleyair.org/Workshops/postings/2012/12-20-

12PM25/FinalVersion/16%20Appendix%20F%20Modeling%20Protocol.pdf

14 Kleeman, M.J., Ying, Q., and Kaduwela, A., 2005, Control strategies for the reduction of airborne particulate nitrate 

in California’s San Joaquin Valley, Atmospheric Environment, 39, 5325-5341.
San Joaquin Valley Unified Air Pollution Control District September 18, 2014

13 Supplemental Documentation: Subpart 4 Requirements

2012 PM2.5 Plan and Rule 2201

generated from VOCs reduces the amount of NO2 that is sequestered, thereby 

increasing the availability of NO2 and enhancing ammonium nitrate formation15. 

For the 2012 PM2.5 Plan, the effectiveness of reducing PM2.5 precursors, including

VOCs, was compared to reducing direct PM2.5 emissions was quantified using interpollutant equivalency ratios16

. Sensitivity analysis was performed for 10% reductions of 

primary PM2.5 as well as for each precursor separately. The change in PM2.5

concentrations per unit emissions change was then determined by dividing the change 

in the 24-hour PM2.5 design value by the amount of emission reductions corresponding 

to the 10% reduction. The equivalency ratios between PM2.5 precursors and primary 

PM2.5 were determined by dividing primary PM2.5 effectiveness by the precursors’ 

effectiveness. 

The results of the modeling runs are plotted on isopleth diagrams, also referred to as 

carrying capacity diagrams. These carrying capacity diagrams show the level of 

emissions that the atmosphere can “carry” and still demonstrate attainment. These 

diagrams help show what combinations of precursor emissions reductions (including 

which precursors are most effective to reduce as well as the magnitude of reductions 

needed) might lead to attainment, informing the development of a corresponding control 

strategy. The carrying capacity diagrams presented in Chapter 4 of the 2012 PM2.5 

Plan (Figures 4-15 through 4-24)

17 show that NOx and directly-emitted PM2.5 are the 

most effective precursors to reduce to improve 24-hour PM2.5 design values, while 

additional VOC reductions do not correspond to improvements in PM2.5 design values. 

3.4.2 VOC Controls 

As noted in section 3.4.1, under subpart 4, regions are required to address VOC as a 

precursor unless EPA determines that VOC sources do not contribute significantly to 

PM concentrations. Extensive scientific research and technical analysis described 

above (and more extensively in the 2012 PM2.5 Plan) demonstrates that VOC

reductions do not contribute to the Valley’s PM2.5 attainment. 

That said, the Valley’s VOC emissions have been significantly reduced through 

stringent District regulations as part of the District’s ozone attainment planning efforts. 

Each District VOC regulation was evaluated in depth for the 2009 RACT SIP18 as well 

as for the 2007 Ozone Plan19. Each VOC rule has also been approved by EPA as 

 

15 Meng, Z., Dabdub, D., and Seinfeld, J.H., 1997, Chemical Coupling Between Atmospheric Ozone and Particulate 

Matter, Science, 277, 116-119.

16 2012 PM2.5 Plan Appendix F (Modeling Protocol), p 127. http://www.valleyair.org/Workshops/postings/2012/12-20-

12PM25/FinalVersion/16%20Appendix%20F%20Modeling%20Protocol.pdf

17 2012 PM2.5 Plan Chapter 4, p 4-31 through 4-40. http://www.valleyair.org/Workshops/postings/2012/12-20-

12PM25/FinalVersion/04%20Chapter%204%20Sci%20Foundation%20and%20Modeling.pdf

18 SJVAPCD (April 16, 2009). Chapter 4: Rule Analysis from the 2009 RACT SIP. Retrieved from: 

http://www.valleyair.org/Air_Quality_Plans/docs/RACTSIP-2009.pdf

19 SJVAPCD (April 2007). 2007 Ozone Plan Appendix I (Candidate Control Measures). Retrieved from: 

http://www.valleyair.org/Air_Quality_Plans/docs/AQ_Ozone_2007_Adopted/26%20Appendix%20I%20April%202007.

pdf
San Joaquin Valley Unified Air Pollution Control District September 18, 2014

14 Supplemental Documentation: Subpart 4 Requirements

2012 PM2.5 Plan and Rule 2201

meeting reasonably available control technology (RACT) levels of emission control 

within the last two years. Table 3 in the District’s 2014 RACT State Implementation 

Plan (SIP)20 lists each of the District’s VOC rules and their respective EPA RACT 

approval date.

Because the science indicates that VOC reductions do not reduce PM2.5 levels, and 

because the nation’s most stringent VOC controls are already in place in the Valley, the

Valley’s VOC emissions do not need to be further reduced to address EPA’s PM2.5 

standard. 

4 REASONABLE FURTHER PROGRESS (RFP)

In CAA Subpart 4, Section 189(c)(1) requires that PM plan submissions to EPA contain 

quantitative milestones which are to be achieved every three years until the area is 

redesignated attainment and which demonstrate RFP toward attainment by the 

applicable date. This requirement is more general than the one specified in EPA’s 2007 

implementation rule21, followed in Section 9.3 of the 2012 PM2.5 Plan. The linear 

progress milestones identified in the 2012 plan can serve as the quantitative milestones 

for subpart 4. 

Table 9-4 in the 2012 PM2.5 Plan identifies target emissions levels for generally linear 

progress that can serve as the quantitative milestones for subpart 4. Table 9-5 in the 

2012 PM2.5 Plan demonstrates that the plan’s adopted control strategy meets these 

quantitative milestones. These milestones are summarized in Table 2 below.

Table 2 Quantitative Milestones

2014 2017

Directly emitted 

PM2.5 73.5 67.6

NOx 315.5 251.4

SOx 10.6 9.6

5 CONTINGENCY MEASURES

5.1 Subpart 4 Contingency Requirements 

Contingency measures are extra emissions reductions that go into effect automatically 

without further regulatory action. In an attainment plan, the measures must be “extra” in 

the sense that the reductions are not accounted for in RFP or in the attainment 

demonstration. The total emissions reductions available from contingency measures 

 

20 SJVAPCD (June 2014) 2014 RACT SIP. Retrieved from: 

http://www.valleyair.org/Board_meetings/GB/agenda_minutes/Agenda/2014/June/final/09.pdf

21 72 FR 20633, codified at 40 CFR 51 Subpart Z Section 51.1000 (Definitions) 
San Joaquin Valley Unified Air Pollution Control District September 18, 2014

15 Supplemental Documentation: Subpart 4 Requirements

2012 PM2.5 Plan and Rule 2201

should be equivalent to about one year of reductions needed for RFP22 as discussed in 

Chapter 9 of the 2012 PM2.5 Plan.

Table 3 Contingency Emissions Reductions Target (tpd)

Contingency Need =

“One year’s worth of RFP”

PM2.5 2.0

NOx 21.4

SOx 0.3

Interpollutant trading can be used to demonstrate equivalent emissions reductions 

levels between PM2.5, NOx, and SOx reductions strategies. Appendix G of the 2012 

PM2.5 Plan documents the methodology used to develop the relative efficacy of 

emission reductions from the different PM2.5 precursors based on photochemical 

modeling sensitivity runs. The current modeling using Valley-wide emissions reductions 

demonstrates that the greatest benefits are achieved from reductions in directly emitted 

PM2.5, followed by NOx (based on EPA’s relative response factor procedures). Kern 

County specific model sensitivity runs were also conducted to evaluate the benefits of 

emission reductions focused on the Bakersfield area. These runs show that directly 

emitted PM2.5 emission reductions are approximately eight times more effective than 

NOx reductions. Additionally, due to the photochemistry of ammonium sulfate 

formation, one ton of SOx reductions is equivalent to one ton of PM2.5 reductions; 

therefore, for contingency purposes, SOx is equivalent to directly emitted PM2.5.

Subpart 4 does not have specific requirements for contingency, so the previouslyidentified RFP milestone years of 2014 and 2017 still apply. Attainment year (2019) 

contingencies no longer apply at this time, since the 2012 PM2.5 Plan is now a request 

for reclassification to serious with the associated attainment year extension to 2019. 

Therefore, the contingency measures demonstration for 2014 and 2017 presented in 

Section 9.4 of the 2012 PM2.5 Plan therefore satisfy subpart 4 requirements, and are 

summarized below. 

5.2 PM2.5 Plan Contingency Demonstration

Contingency measures can include measures already adopted and scheduled for 

implementation, as long as these measures are not relied on to provide emissions 

reductions needed to provide for RFP or expeditious attainment. For 2014 and 2017, 

the District is utilizing two types of contingency measures:

1. Surplus reductions from implementation of traditional regulations

2. SIP-creditable incentive-based emissions reductions

 

22 Clean Air Fine Particle Implementation Rule [PM2.5 Implementation Rule]. 72 Fed. Reg. 79, pp. 20586–20667. At 

20642-43. (2007, April 25). Retrieved from http://www.gpo.gov/fdsys/pkg/FR-2007-04-25/pdf/E7-6347.pdf#page=1
San Joaquin Valley Unified Air Pollution Control District September 18, 2014

16 Supplemental Documentation: Subpart 4 Requirements

2012 PM2.5 Plan and Rule 2201

5.2.1 Surplus Reductions from Implementation of Traditional Regulations

Although contingency measures must be surplus to RFP and attainment calculations, 

areas are not required to wait until there is an RFP or attainment failure to implement 

the measures. As shown in the RFP demonstration in chapter 9 of the 2012 PM2.5 

Plan, significant regulatory emissions reductions are being achieved by 2014 and 2017 

– more than the minimum needed to demonstrate RFP. As such, the difference 

between the RFP target emissions level and the actual projected emissions level can 

serve as contingency reductions in 2014 and 2017. The following table shows the 

amount of reductions available in 2014 and 2017, as documented in Chapter 9 of the 

2012 PM2.5 Plan.

Table 4 Reductions Surplus to RFP for Contingency (tpd)

(Table 9-7 in the 2012 PM2.5 Plan) 

Year

2014 2017

RFP target 

emissions 

level

Projected 

emissions 

inventory

Contingency

RFP target 

emissions 

level

Projected 

emissions 

inventory

Contingency

PM2.5 73.5 64.4 9.1 67.6 63.2 4.4

NOx 315.5 275.7 39.8 251.4 226.9 24.5

SOx 10.6 8.6 2.0 9.6 8.8 0.8

The control measures achieving the contingency reductions include amendments to 

Rule 4692 (Commercial Charbroiling), ARB mobile source measures and adopted 

stationary and area source measures such as District Rule 4307 (Boilers, Steam 

Generators, and Process Heaters – 2.0 MMBtu/hr to 5.0 MMbtu/hr), Rule 4308 (Boilers, 

Steam Generators, and Process Heaters- 0.075 MMBtu/hr to less than 2.0 MMBtu/hr), 

Rule 4320 (Advanced Emission Reduction Options for Boilers, Steam Generators, and 

Process Heaters Greater than 5.0 MMBtu/hr), Rule 4702 (Internal Combustion 

Engines), and Rule 4103 (Open Burning). All of the aforementioned control measures 

are discussed in detail in Chapter 9 of the 2012 PM2.5 Plan. 

5.2.2 Sufficient Contingency Reductions

The following table shows how the abovementioned combination of approaches 

reduces enough emissions to meet contingency requirements for 2014 and 2017.
San Joaquin Valley Unified Air Pollution Control District September 18, 2014

17 Supplemental Documentation: Subpart 4 Requirements

2012 PM2.5 Plan and Rule 2201

Table 5 Demonstration of Sufficient Contingency Reductions, 2014 and 2017 

(based on Table 9-9 of the 2012 PM2.5 Plan)

2014 2017 PM2.5 Plan Data reference23

PM2.5

Surplus from traditional regulations 9.1 4.4 Tables 9-7 and 9-8

Regulations with contingency trigger 0 0 Section 9.4.1.2

Subtract PM2.5 reductions, trade for SOx 0 0 1:1 trading ratio*

Subtract PM2.5 reductions, trade for NOx 1:8 trading ratio*

Total contingency reductions achieved 9.1 4.4

Contingency reductions required 2.0 Table 9-6

Contingency need met? Yes Yes

NOx

Surplus from traditional regulations 39.7 24.4 Tables 9-7 and 9-8

Regulations with contingency trigger 0 0 Section 9.4.1.2

SIP-creditable incentives 0 0 Section 9.4.1.3

Substitute PM2.5 reductions Above, with 1:8 trading ratio*

Total contingency reductions achieved 39.7 24.4

Contingency reductions required 21.4 Table 9-6

Contingency need met? Yes Yes

Sox

Surplus from traditional regulations 2.0 0.8 Tables 9-7 and 9-8

Regulations with contingency trigger 0 0 Section 9.4.1.2

SIP-creditable incentives 0 0 Section 9.4.1.3

Substitute PM2.5 reductions Above, with 1:1 trading ratio*

Total contingency reductions achieved 2.0 0.8

Contingency reductions required 0.3 Table 9-6

Contingency need met? Yes Yes

* 1 ton of direct PM2.5 emissions reductions is equivalent to 1 ton of SOx reductions or 8 tons of NOx reductions as demonstrated in 

the Weight of Evidence (Appendix G). These ratios are conservative estimates summarizing the plan as a whole, not reflecting 

ratios appropriate for New Source Review (NSR)

6 NEW SOURCE REVIEW PROGAM

On April 21, 2011, the District’s NSR rule (Rule 2201) was amended to address the 

federal PM2.5 nonattainment NSR permitting requirements of subpart 1. These 

amendments were based on EPA’s two final rules called “Clean Air Fine Particle 

Implementation” (promulgated on April 25, 2007, 72 FR20586) and “Implementation of 

the New Source Review (NSR) Program for Particulate Matter Less than 2.5 Microns” 

(PM2.5 NSR Rule) requirements (promulgated on May 16, 2008, 73 FR28321) which 

outlined the necessary requirements of subpart 1 of Part D of Title I of the CAA. Items 

 

23 SJVUAPCD. 2012 PM2.5 Plan. Retrieved on 4/11/14 from 

http://www.valleyair.org/Air_Quality_Plans/PM25Plan2012/CompletedPlanbookmarked.pdf. 
San Joaquin Valley Unified Air Pollution Control District September 18, 2014

18 Supplemental Documentation: Subpart 4 Requirements

2012 PM2.5 Plan and Rule 2201

addressed in the April 2011 amendments to Rule 2201 included defining major sources 

of PM2.5 at 100 tons per year, establishing PM2.5 significant emissions rates to 

determine when NSR requirements apply to modified sources, establishing the PM2.5 

offset ratio, and allowing for PM2.5 interpollutant emission offset ratios. The District’s 

April 2011 NSR amendments fulfilled the necessary NSR SIP requirements previously 

established by EPA as necessary under subpart 1.

EPA then issued its June 2, 2014 PM2.5 final rule in response to a remand from the 

D.C. Circuit Court of Appeals in January 2013 which, in part, required that subpart 4 be 

applied to PM2.5 permitting programs, rather than subpart 1. Under this final rule, the 

District must demonstrate that its permitting program satisfies the nonattainment new 

source review SIP elements pursuant to subpart 4 of the federal CAA. EPA set a 

deadline of December 31, 2014 for such submittals. 

EPA’s rulemaking clarifying NSR requirements for PM2.5 under subpart 4 is 

forthcoming, but, unfortunately, will not be proposed until late summer or fall of 2014. It

is not expected to be finalized until several months thereafter. Waiting for EPA to 

finalize its NSR rulemaking would not allow the District sufficient time to meet the 

December 31, 2014 deadline. Rather than await EPA’s rulemaking and, as a result, 

missing federal rule development deadlines, this document describes how the District 

already satisfies subpart 4 requirements for NSR. 

As described in this document, no additional NSR SIP elements or NSR rule 

modifications are necessary to augment the District’s previous NSR SIP submittal

pursuant to subpart 1. This document demonstrates that the existing NSR rule, as 

adopted by the District on April 21, 2011, meets all subpart 4 requirements.

6.1 Permitting PM2.5 Precursors at Major Sources

Section 189(e) of subpart 4 of the CAA requires the control of PM10 precursors at major 

stationary sources “except where the Administrator determines that such sources do not 

contribute significantly to PM10 levels which exceed the standard in the area.” 

PM2.5 precursors are emissions of NOx, SOx, VOC and ammonia that contribute to 

PM2.5 formation. Under Rule 2201, section 3.31, NOx and SOx are currently identified 

and controlled as precursors to PM2.5, and thus Rule 2201 meets the requirements of 

subpart 4 with respect to NOx and SOx as precursors. In the Valley, however, VOC

and ammonia are not considered precursors that contribute significantly to the formation 

of PM2.5 pertaining to NSR permitting requirements. 

The CAA recognized that there may be circumstances in which it is not appropriate to 

subject certain precursors, such as ammonia and VOC, to permitting control 

requirements. Based on the scientific data and modeling analyses outlined in the 

District’s 2012 PM2.5 Plan, summarized in Section 3 of this document, VOC and 

ammonia do not significantly contribute to PM2.5 formation in the Valley. 
San Joaquin Valley Unified Air Pollution Control District September 18, 2014

19 Supplemental Documentation: Subpart 4 Requirements

2012 PM2.5 Plan and Rule 2201

6.1.1 Ammonia

As stated previously, the District is required to address ammonia as a precursor unless 

it is determined that ammonia sources do not contribute significantly to PM 

concentrations. The District’s 2012 PM2.5 Plan, as summarized in section 3.3 of this 

document, demonstrates that control of ammonia emissions does not contribute 

significantly to PM2.5 attainment. Therefore, ammonia need not be addressed as a 

precursor to PM2.5 in the District’s NSR program.

6.1.2 VOC 

Similarly, the District demonstrates in the 2012 PM2.5 Plan and summarizes in section 

3.4 of this document that VOC does not contribute significantly to the formation of 

PM2.5 and therefore does not need to be addressed as a PM2.5 precursor in the 

District’s NSR program. 

Although VOC is not a significant contributor to PM2.5 in the Valley, Rule 2201 provides 

for the regulation of VOC as a precursor to ozone. The level to which major sources of 

VOC are controlled in the District’s NSR rule is extensive, since the Valley is classified 

as an extreme nonattainment area for ozone. VOC sources in the Valley are major 

sources at 10 tpy, have an emission offset threshold of 10 tpy, have a distance offset 

ratio of 1.5 to 1 for new major sources of federal major modification, require BACT if 

daily emissions exceed 2 pounds per day, and have a significant modification level set 

to zero for federal major modifications. Therefore, VOC as an ozone precursor is 

controlled through the District’s NSR rule at levels much lower than if they would be 

controlled as a PM2.5 precursor.

6.2 Major Source and Major Modification Thresholds

On June 2, 2014, EPA classified the Valley as a “moderate” nonattainment area for 

PM2.5 under subpart 4. Under this classification, major sources of PM2.5 are defined 

as sources with a potential to emit equal to or greater than 100 tons per year (tpy). Rule 

2201, as amended April 2011, includes this threshold. 

In addition, Rule 2201 specifically identifies SOx and NOx as precursors of PM2.5, and 

includes appropriate thresholds for determining whether proposed emission increases 

of PM2.5, SOx or NOx constitute a major modification of a major PM2.5 source under 

subpart 4. Rule 2201 also includes all the appropriate federal requirements for 

proposed major sources and major modifications (notification, BACT, offsets, etc.), none 

of which are specific to subpart 4 and are therefore already included in the latest SIPapproved version of Rule 2201.

7 CONCLUSION 

As shown in this supplemental document, the 2012 PM2.5 Plan satisfies all subpart 4 

requirements and demonstrates that attainment by 2015 is not practicable. The District 
San Joaquin Valley Unified Air Pollution Control District September 18, 2014

20 Supplemental Documentation: Subpart 4 Requirements

2012 PM2.5 Plan and Rule 2201

formally requests EPA approve said plan and reclassify the Valley as a serious area. 

Serious area requirements will be addressed after the Valley is redesignated by EPA as 

a serious area and will be in conjunction with the District’s 2016 air quality attainment 

plan. 

In addition, this document demonstrates that the District’s April 21, 2011 version of Rule 

2201 (New and Modified Stationary Source Review Rule) fully complies with and 

satisfies subpart 4 requirements. The District formally requests that EPA approve this 

rule as satisfying NSR requirements for PM2.5 under subpart 4 for moderate 

nonattainment areas for both the 1997 and 2006 standards.
San Joaquin Valley Unified Air Pollution Control District September 18, 2014

A-1 Attachment A, Supplemental Documentation: Subpart 4 Requirements

2012 PM2.5 Plan and Rule 2201

Attachment A: Ammonia Controls

Under subpart 4, regions are required to address ammonia as a precursor in RACT 

analyses and other areas of the plan unless EPA determines that ammonia sources do 

not contribute significantly to PM concentrations. To improve public health while also 

ensuring effective use of resources, additional ammonia controls should only be 

required when there is clear scientific evidence that reasonable measures to reduce 

ammonia emissions would be effective in significantly reducing ambient PM2.5 

concentrations.

Extensive scientific research and technical analysis described above (and more 

extensively in the 2012 PM2.5 Plan) demonstrates that ammonia reductions do not 

contribute to the Valley’s PM2.5 attainment. That said, this section shows that the 

Valley’s ammonia emissions have been significantly reduced through stringent District 

regulations. This section also shows that additional ammonia reductions are infeasible. 

Because the science indicates that ammonia reductions do not contribute to the Valley’s 

PM2.5 attainment, and because additional ammonia controls are infeasible, the Valley’s 

ammonia emissions do not need to be further reduced to address EPA’s PM2.5 

standard. 

As demonstrated in Appendix B of the 2012 PM2.5 Plan, the three main sources of 

ammonia emissions in the Valley from stationary and area sources account for 96% of 

the Valley’s ammonia emissions are as follows (based on 2015 estimates):

 Farming Operations with 239.2 tons per day (tpd), 

 Solvent evaporation from Agricultural Fertilizers at 66.1 tpd, and 

 Composting Solid Waste Operations at 20.5 tpd.

The following discussion evaluates:

 Confined Animal Facilities (District Rule 4570)

 Agricultural Fertilizers

 Organic Material Composting (District Rule 4566)

 Biosolids, Animal Manure, and Poultry Litter Operations (District Rule 4565)

 Major Sources of Ammonia

A.1 Confined Animal Facilities (District Rule 4570)

I. District Rule Description:

District Rule 4570, was originally adopted on June 15, 2006 and was most recently 

amended on October 21, 2010. The purpose of this rule is to limit emissions of volatile 

organic compounds (VOC) from Confined Animal Facilities (CAF). District Rule 4570

applies to facilities where animals are corralled, penned, or otherwise caused to remain in 

restricted areas and primarily fed by a means other than grazing for at least 45 days in any 

twelve-month period. In addition to limiting VOC emissions, District Rule 4570 also 

includes measures that limit ammonia (NH3) emissions from these operations; the 
San Joaquin Valley Unified Air Pollution Control District September 18, 2014

A-2 Attachment A, Supplemental Documentation: Subpart 4 Requirements

2012 PM2.5 Plan and Rule 2201

required measures have also reduced ammonia emissions by over 100 tpd24 (this 

reduction is already reflected in the emissions inventory data above). The analysis

below focuses on how District Rule 4570 limits NH3 emissions in comparison to other 

rules and regulations.

A. Types of Confined Animal Facilities

Confined Animal Facilities are used for the raising of animals including, but not limited 

to, cattle, calves, chickens, ducks, goats, horses, sheep, swine, rabbits, and turkeys, 

which are corralled, penned, or otherwise caused to remain in restricted areas for 

commercial agricultural purposes and fed by a means other than grazing. (CH&SC 

39011.5 (a)(1)). The major categories of Confined Animal Facilities are listed below.

 Dairy Operations - Dairy operations are those operations producing milk or animals 

for facilities that produce milk. 

 Poultry Operations - Poultry facilities operate either as layer ranches for egg 

production or as broiler ranches where birds are grown for the fresh meat market.

 Beef Cattle Feeding Operations – Beef cattle facilities are facilities that raise beef 

cattle (heifers and steers) for their meat.

 Swine Operations – These operations raise pigs for their meat. The production 

cycle for hogs has three (3) phases: farrowing (giving birth), nursing, and finishing. 

B. Rule 4570 Applicability Thresholds

The thresholds for a facility to be classified as a large CAF in the San Joaquin Valley 

and the thresholds for a facility to be subject to District Rule 4570 are shown in the 

following table. The large CAF thresholds are based on the definition of a large CAF 

adopted by the California Air Resources Board (ARB) as required by California Senate 

Bill (SB) 700. District Rule 4570 applies to confined animal facilities that have the 

capacity to house a number of animals equal to or exceeding the Rule 4570 regulatory 

thresholds, which are lower than the large CAF thresholds for certain facilities.

 

24

 Appendix F of the Staff Report for the June 2009 re-adoption of Rule 4570, starting on the 329th page of the pdf 

available here 

http://www.valleyair.org/Board_meetings/GB/agenda_minutes/Agenda/2009/June/Agenda%20Item_10_June_18_200

9.pdf
San Joaquin Valley Unified Air Pollution Control District September 18, 2014

A-3 Attachment A, Supplemental Documentation: Subpart 4 Requirements

2012 PM2.5 Plan and Rule 2201

Rule 4570 Thresholds for Regulation

Livestock Category SJVAPCD Large CAF 

Thresholds

Rule 4570

Regulatory Thresholds

Dairy 1,000 milking cows 500 milking cows

Beef Feedlots 3,500 beef cattle 3,500 beef cattle

Other Cattle Facility 7,500 calves, heifers, or 

other cattle

7,500 calves, heifers, or other 

cattle

Poultry Facilities

Chicken 650,000 head 400,000 head

Duck 650,000 head 400,000 head

Turkey 100,000 head 100,000 head

Swine Facility 3,000 head 3,000 head

Horses Facility 3,000 head 3,000 head

Sheep and Goat 

Facilities

15,000 head of sheep, goats, 

or any combination of the two

15,000 head of sheep, goats, 

or any combination of the two

Any livestock facility 

not listed above 30,000 head 30,000 head

C. Emission Control Requirements of District Rule 4570

District Rule 4570 requires multiple mitigation measures from the following CAF 

categories: Dairy, Beef Feedlots, Other Cattle Facilities, Swine Facilities, Poultry 

facilities, and various other smaller operations. Each of these facilities consists of 

multiple sources of emissions within the facility. Since these facilities generally cover a 

large area and have different processes, a single mitigation measure or technology is 

generally not sufficient to control overall emissions from the facility. Mitigation 

measures required by Rule 4570 have been tailored for each source of emissions, 

thereby ensuring that the overall emissions from a facility are reduced. The current 

methodology in Rule 4570 allows for the greatest overall control from the entire facility.

District Rule 4570 recognized the following five emission sources for all of the CAFs: 

Feed, Housing, Solid Waste, Liquid Waste, and Land Application of Manure. Rule 4570 

requires each CAF to implement a certain number of mitigation measures for each of 

these sources. District Rule 4570 also distinguishes between the different types of 

housing configurations (freestall vs open corrals) for cattle and, as such, requires 

specific mitigation measures for each type of housing. By requiring mitigation 

measure(s) for each source of emissions at a facility, District Rule 4570 ensures that 

reductions are achieved throughout the facility. 

The following describes some of the mitigation measures and the ways in which these 

measures reduce ammonia emissions: 

 Nutritional management: Ammonia emissions result from the decomposition of 

undigested nitrogen compounds in animal waste. Proper nutritional 

management, with diets formulated to feed proper amounts of protein, improves 

nitrogen utilization by the animal, reducing production of ammonia from animal 

waste.
San Joaquin Valley Unified Air Pollution Control District September 18, 2014

A-4 Attachment A, Supplemental Documentation: Subpart 4 Requirements

2012 PM2.5 Plan and Rule 2201

 Increased cleaning and removal of manure and litter from animal housing areas: 

Because animal waste is the primary source of ammonia emissions, increased 

removal of waste from animal housing areas will reduce emissions by reducing 

the exposed area. Proper management of the waste will stabilize the nitrogen 

compounds in the waste, which will reduce the rate that these compounds are 

converted to ammonia that can be lost to the atmosphere. In addition, ammonia 

is highly soluble in water; therefore, when a flush system is used, ammonia 

emissions will be reduced because much of the ammonia will dissolve in the 

water rather than volatilize to the air.

 Incorporation of manure into fields: Incorporation of manure in fields reduces 

volatilization of gaseous pollutants by minimizing the amount of time that the 

manure is exposed to the atmosphere. Once the waste has been incorporated 

into the soil, VOCs and ammonia are absorbed onto soil particles, providing the 

opportunity for these soil microbes to oxidize these compounds into carbon 

dioxide, water, and nitrates.

One area to which some of these rules may apply is silage and silage-based total mixed 

ration (TMR) used as feed for cattle. Research has demonstrated that silage and TMR 

are one of the largest sources of VOC emissions at cattle facilities but are not significant 

sources of NH3 emissions, which primarily results from the animal waste at Confined 

Animal Facilities; therefore, the measures that specifically apply to management of 

silage and TMR will not be discussed in detail in this analysis.

II. How does District Rule 4570 compare with federal rules and regulations?

A. EPA-Control Technique Guidelines (CTG)

There is no EPA CTG guidance document for confined animal facilities.

B. EPA - Alternative Control Technology (ACT)

There is no EPA ACT guidance document for confined animal facilities.

C. Standards of Performance for New Stationary Sources (NSPS)

There is no NSPS guidance document for guidance document for confined 

animal facilities.

D. National Emission Standards for Hazardous Air Pollutants (NESHAPs) and 

Maximum Achievable Control Technologies (MACTs)

There is no NESHAP guidance document for confined animal facilities.

III. How does District Rule 4570 compare to rules in other air districts?
San Joaquin Valley Unified Air Pollution Control District September 18, 2014

A-5 Attachment A, Supplemental Documentation: Subpart 4 Requirements

2012 PM2.5 Plan and Rule 2201

As the largest agricultural area in California, the District took the lead in devising a list of 

mitigation measures for the various emission sources during the initial development of 

District Rule 4570. This list of mitigation measures was essentially utilized, almost 

identically, by all air districts in their rules. However, during the last amendments to 

District Rule 4570, all of the mitigation measures were reevaluated in light of the latest 

available science. In comparison to the previous version of the rule, the current rule

lowered threshold limits to bring in additional CAFs, requires additional mitigation 

measures, clarified previous mitigation measures, and added additional monitoring, 

testing, and recordkeeping to improve enforceability. 

The following California air district rules were compared to District Rule 4570: 

 South Coast AQMD Rule 223, adopted June 2, 2006

 South Coast AQMD Rule 1127, adopted August 6, 2004

 Bay Area AQMD Regulation 2 Rule 10, adopted July 19, 2006

 Ventura County APCD Rule 23 (Exemptions), amended April 8, 2008

 Sacramento Metropolitan AQMD Rule 496, adopted August, 24, 2006

 Imperial County APCD Rule 217 and Policy 38, adopted October 10, 2006

 Butte County AQMD Rule 450, adopted December 21, 2006

Idaho Administrative Procedure Act (IDAPA) 58.01.01 Sections 760-764 was also 

compared with District Rule 4570 and the analysis is shown below. 

It is important to note that only District Rule 4570, Sacramento Metropolitan AQMD Rule 

496, and South Coast AQMD Rule 1127 are prohibitory rules. For this reason, these 

rules include detailed recordkeeping as well as monitoring and testing requirements. 

Generally, the level of detail in a prohibitory rule is absent from permits rules because 

the purpose of a permit rule is different from the purpose of a prohibitory rule.

A. South Coast AQMD (SCAQMD) Rule 223

Applicability/Exemption/Large CAF Definition

SCAQMD Rule 223 was adopted on June 2, 2006 and has not been amended. 

SCAQMD Rule 223 applies to large CAFs as defined by ARB. District Rule 4570 

defines large CAFs the same way except for large CAFs for horses. District Rule 

4570 defines a large CAF for horses as having at least 3,000 head, whereas 

SCAQMD Rule 223 defines a large CAF for horses as having at least 2,500 

head. There are currently no CAFs in the San Joaquin Valley with the capacity 

to house at least 2,500 horses and no CAFs for horses in the San Joaquin Valley 

are expected to exceed this threshold in the foreseeable future.

In addition to applying to large CAFs, District Rule 4570 lowers the applicability 

thresholds for the following CAFs:

 Dairies – from 1,000 milk cows to 500 milk cows 
San Joaquin Valley Unified Air Pollution Control District September 18, 2014

A-6 Attachment A, Supplemental Documentation: Subpart 4 Requirements

2012 PM2.5 Plan and Rule 2201

 Broilers/Ducks and Layers – from 650,000 birds to 400,000 birds

Therefore, Rule 4570 is more stringent regarding applicability.

Requirements for Dairy CAFs

Feed Mitigation Measures

District Rule 4570 has seven mitigation measures for feed and two mitigation 

measures for silage. Operators must implement four mandatory feed mitigation 

measures and chose another one from a list of three, for a total of five mitigation 

measures required for feed. In the SCAQMD rule, there are nine feed mitigation 

measures, from which the operator must implement five. Both rules require 

selection of five mitigation measures for feed, excluding silage, but four of the 

five feed mitigation measures are mandatory in District Rule 4570. Therefore, 

overall District Rule 4570 is more stringent.

Milk Parlor Mitigation Measures

The milk parlor mitigation measures for SCAQMD includes one Class One and 

one Class Two mitigation measure. District Rule 4570 contains the same 

mitigation measures included in the SCAQMD rule as Class One and has 

removed the Class Two mitigation measures due to infeasibility; see the Staff 

Report for the October 21, 2010 amendments to Rule 4570 for more detail. 

Therefore, both rules will be considered identical in this category.

Freestall Mitigation Measures

District Rule 4570 has five mitigation measures, two of which are mandatory. 

The facility is also required to choose one additional mitigation measure from the 

remaining three. SCAQMD Rule 223 has eight Class One mitigations measures, 

from which facilities are required to implement at least two. District Rule 4570 

requires one additional mitigation measure; therefore, District Rule 4570 is more 

stringent. 

SCAQMD Rule 223 has three Class One mitigation measures that require 

increased frequency in comparison to the corresponding District Rule 4570 

measures: (inspect water pipes and troughs and repair leaks; remove animal 

waste that is not dry from individual cow freestall beds; and rake, harrow, scrape, 

or grade bedding in freestalls). The South Coast rule requires pipes and troughs 

to be inspected daily, and manure from freestall beds to be removed daily, 

whereas District Rule 4570 does not require inspection of pipes and troughs in 

freestall barns. In the San Joaquin Valley the majority of freestall barns use flush 

systems for manure management and may also use misters or water sprays to 

keep animals cool; therefore, inspection of the pipes and troughs in the freestall 

barns was determined to be irrelevant since this is already a wet system. 
San Joaquin Valley Unified Air Pollution Control District September 18, 2014

A-7 Attachment A, Supplemental Documentation: Subpart 4 Requirements

2012 PM2.5 Plan and Rule 2201

SCAQMD Rule 223 requires freestall beds to be raked/harrowed/graded at least 

twice every seven days, whereas District Rule 4570 requires this measure to be 

carried out once every 7 days for large dairies and once every 14 days for 

medium dairies. Although, SCAQMD Rule 223 has a higher frequency for these 

measures, the emissions generated from these sources are not significant, 

including the reductions achieved from the overall dairy. In addition, the CAF 

stakeholders have questioned the cost effectiveness of a daily frequency. Based 

on the above, the increased frequency required by SCAQMD Rule 223 can be 

considered to exceed RACT requirements.

Corral Mitigation Measures

District Rule 4570 has nine mitigation measures, six of which are mandatory. 

The facility is also required to choose one additional mitigation measure from the 

remaining three. SCAQMD Rule 223 has 14 Class One mitigation measures and 

two Class Two mitigation measures, from which facilities are required to choose 

at least six. District Rule 4570 requires one additional mitigation measure; 

therefore, District Rule 4570 is more stringent. 

SCAQMD Rule 223 has one Class One mitigation measure (inspect water pipes 

and troughs and repair leaks) that require increased frequency in comparison to 

the corresponding District Rule 4570 measure. SCAQMD Rule 223 requires this 

measure to be carried out daily, whereas District Rule 4570 requires it to be 

carried out only once every seven days. Although, SCAQMD Rule 223 has a 

higher frequency for this measure, the difference in the emissions reductions 

from the two frequencies is not expected to be significant. In addition, as 

discussed earlier the frequency required by SCAQMD Rule 223 exceeds RACT 

when compared to inspection leak requirements in other rules and regulations.

Solid Waste and Separated Solids Mitigation Measures

District Rule 4570 contains only two mitigation measures, from which operators 

are required to choose at least one. SCAQMD Rule 223 has three Class One 

mitigation measures and three Class Two mitigation measures, from which 

facilities are required to choose at least two. 

Available studies have indicated that NH3 emissions from stored solid waste and 

separated solids pile to be a very small fraction of total NH3 emissions at dairies. 

Since the NH3 emissions from solid manure account for a very small fraction of 

emissions from the overall dairy, there would not be a significant increase in NH3

emission reductions if more measures are required from this category. 

Liquid Waste Mitigation Measures

District Rule 4570 has four mitigation measures, from which operators are 

required to choose at least one. SCAQMD Rule 223 has five Class One 
San Joaquin Valley Unified Air Pollution Control District September 18, 2014

A-8 Attachment A, Supplemental Documentation: Subpart 4 Requirements

2012 PM2.5 Plan and Rule 2201

mitigation measures and five Class Two mitigation measures, from which 

operators are required to choose at least one. Since only one measure is 

required by both rules, the rules are similar in stringency.

Manure Land Application Mitigation Measures

District Rule 4570 has two mitigation measures required out of six optional 

measures. SCAQMD Rule 223 has four mitigation measures, from which 

facilities are required to choose at least two. All the mitigation measures are 

similar in stringency.

Requirements for Poultry CAFs

There is a large degree of variability in the manure management practices, 

housing techniques, and potential feeding practices for the different type of 

poultry operations in the San Joaquin Valley. Due to these differences, District 

Rule 4570 separates poultry CAFs into the following categories: 1) layers and 2) 

broilers, ducks, and turkeys. 

Although on the surface the poultry requirements results in fewer mitigation 

measures compared to the other rules, the segregating of the types of poultry 

has allowed the mitigation measures to be tailored specifically to the type of 

poultry operation. In addition, all measures for poultry in District Rule 4570 are 

now mandated rather than left as options. Due to this reconfiguration and taking 

into consideration the latest science, the District Rule 4570 requirements for 

poultry are more stringent than SCAQMD Rule 223.

Requirements for Other CAF Categories

In addition to dairy and poultry CAF mitigation measures discussed above, 

District Rule 4570 provides specific mitigation measures for beef cattle feedlots, 

other cattle, and swine CAFs. SCAQMD Rule 223 does not address mitigation 

measures for these additional CAF categories. For these types of large CAFs, 

District Rule 4570 is more stringent.

Requirements – Suspension and Substitution of Mitigation Measures

Both rules allow the temporary suspension of a mitigation measure upon the 

determination by a certified veterinarian or nutritionist that such a suspension is 

necessary for animal health purposes. The District must be notified within 48 

hours, and a new measure must be implemented if the suspension is expected to 

last longer than 30 days. In addition, both rules allow for substitution of one 

mitigation measure with an equivalent or more stringent one with the submission 

of the appropriate information. Therefore, the suspension and substitution 

requirements of both rules are equally stringent.
San Joaquin Valley Unified Air Pollution Control District September 18, 2014

A-9 Attachment A, Supplemental Documentation: Subpart 4 Requirements

2012 PM2.5 Plan and Rule 2201

Conclusion – Comparison with South Coast AQMD Rule 223

Based on the analysis of the CAF categories in District Rule 4570 and SCAQMD 

Rule 223, it is clear that District Rule 4570 is more stringent than SCAQMD Rule 

223. There are differences in the frequency with which some mitigation 

measures are to be implemented. However, as stated earlier, many of these 

sources are a small portion of a dairy’s overall emissions. The amended version 

of District Rule requires facilities to choose more mitigation measures and makes 

several mitigation measures mandatory. 

District Rule 4570 also provides mitigation for more CAF categories (beef 

feedlots, other cattle, and swine) that are not addressed by SCAQMD Rule 223, 

and also has much more detailed recordkeeping requirements to demonstrate 

implementation of selected mitigation measures. In addition, SCAQMD recently 

identified District Rule 4570 as the most stringent rule for this source category in 

their ozone Reasonably Available Control Technology (RACT) Demonstration.[25]

B. South Coast AQMD (SCAQMD) Rule 1127

Applicability/Exemption/Large CAF Definition

SCAQMD Rule 1127 was adopted on August 4, 2004 and has not been 

amended. 

SCAQMD Rule 1127 applies to dairies with 50 or more cows, heifers, and/or 

calves. The rule applies to dairy farms and related operations such as heifer and 

calf farms and the manure produced on them. By comparison, District Rule 4570 

applies to dairy CAFs with at least 500 milking cows, but applies to more than 

just manure-handling operations. Although the SCAQMD Rule has a lower 

applicability threshold, the overall control effectiveness of Rule 1127 when 

compared to District Rule 4570, is far less stringent.

Requirements for Dairy CAFs

Milking Parlor and Freestall Mitigation Measures

For the milking parlor, the District rule has one mandatory mitigation measure. 

District Rule 4570 has five mitigation measures for freestalls, two of which are 

mandatory. The facility is also required to choose one additional mitigation 

measure from the remaining three to implement. SCAQMD Rule 1127 does not 

address these operations. Therefore, overall District Rule 4570 is more stringent 

than SCAQMD Rule 1127.

 

25 South Coast Air Quality Management District (June 6, 2014). Reasonably Available Control Technology 

Demonstration. http://www.aqmd.gov/docs/default-source/Agendas/Governing-Board/2014/2014-jun6-

031.pdf?sfvrsn=2
San Joaquin Valley Unified Air Pollution Control District September 18, 2014

A-10 Attachment A, Supplemental Documentation: Subpart 4 Requirements

2012 PM2.5 Plan and Rule 2201

Corral Mitigation Measures

District Rule 4570 has nine mitigation measures, six of which are mandatory. 

The facility is also required to choose one additional mitigation measure from the 

remaining three. SCAQMD Rule 1127 has eight mitigation measures, from which 

facilities are required to choose at least six. The mitigation measures required by 

SCAQMD Rule 1127 specify the removal of manure from the corrals, the 

minimization of water in the corrals, and the cleaning schedule and cleaning 

strategy for the corrals. While the mitigation measures in the two rules are not 

phrased the same way, they cover similar requirements. District Rule 4570 

requires one additional measure; therefore, Rule 4570 is more stringent.

Solid Waste, Separated Solids, and Liquid Waste, and Manure Land Application 

Mitigation Measures

District Rule 4570 has two mitigation measures for solid waste/separated solids, 

from which operators are required to choose at least one. For liquid waste, 

District Rule 4570 has four mitigation measures for liquid waste, from which 

operators are required to choose at least one. District Rule 4570 has two 

mitigation measures for land application of manure required out of six optional 

measures. SCAQMD Rule 1127 states that manure removed must be either 

treated at an approved manure processing operation, or applied on agricultural 

land with local approval. SCAQMD Rule 1127 does not specify different 

mitigation measures for solid waste, separated solids, or liquid waste. District 

Rule 4570 has specific mitigation measures for each of these operations; 

therefore, it is able to better target the reduction of emissions from these the 

different operations. District Rule 4570 is therefore as stringent as or more 

stringent than SCAQMD Rule 1127.

Requirements for Other CAFs

District Rule 4570 provides specific mitigation measures for beef cattle feedlots, 

other cattle facilities, poultry facilities, and swine facilities. SCAQMD Rule 1127 

does not address mitigation measures for these additional CAF categories. 

Therefore, District Rule 4570 is more stringent for this category.

Requirements – Suspension and Substitution of Mitigation Measures

SCAQMD Rule 1127 provides one exemption per year from one of the corral 

clearings required every 90 days if the moisture content in the corrals is greater 

than 50%. The operator is required to notify SCAQMD 30 days before the 

required cleaning, and test moisture content weekly. If moisture content is still 

above 50% when the cleaning is due, the operator may claim the exemption.

In comparison, District Rule 4570 allows an operator to temporarily suspend any 

mitigation measure as long as the suspension is recommended by a licensed 
San Joaquin Valley Unified Air Pollution Control District September 18, 2014

A-11 Attachment A, Supplemental Documentation: Subpart 4 Requirements

2012 PM2.5 Plan and Rule 2201

veterinarian of animal nutritionist on the basis of animal health. The operator 

must notify the District within 48 hours prior to the suspension. If the suspension 

is expected to last longer than 30 days, then the operator must submit a new 

mitigation plan that identifies a new mitigation measure to be implemented in 

place of the suspended one.

District Rule 4570’s exemption under this category is much more stringent 

because it is only a temporary suspension that cannot exceed 30 days, whereas 

SCAQMD Rule 1127’s exemption may be permanent, without any requirement to 

substitute another measure. 

Therefore, in this category of mitigation measure suspensions/substitutions, 

District Rule 4570 is more stringent than SCAQMD Rule 1127. 

Testing, Monitoring, Recordkeeping Requirements

Both SCAQMD Rule 1127 and District Rule 4570 require monitoring, record 

keeping and source testing as appropriate and sufficient to provide evidence of 

each mitigation measure being implemented.

In addition to record keeping, Rule 1127 requires an annual report of manure 

being shipped out from the dairy. No annual reporting is required by Rule 4570. 

Rule 1127 requires records be retained for 3 years for minor sources and 5 years 

for major sources, whereas Rule 4570 requires records be retained for five years 

for all sources.

Overall, the monitoring, testing and record keeping requirements are similar for 

both rules.

Conclusion – Comparison with South Coast AQMD Rule 1127

For dairy CAFs, District Rule 4570 is more stringent than SCAQMD Rule 1127. 

District Rule 4570 requires emission reductions from additional emission 

categories - milk parlors, freestall barns, and liquid manure - that are not 

addressed by SCAQMD Rule 1127 as well as requiring emission reductions from 

CAFs from other animal species. As mentioned above, the current version of 

District Rule 4570 requires facilities to choose more mitigation measures and

makes several mitigation measures mandatory. District Rule 4570 also provides 

specific mitigation measures for beef cattle feedlots, other cattle, poultry, and 

swine CAFs, while SCAQMD Rule 1127 does not. District Rule 4570 is, 

therefore, more stringent than SCAQMD Rule 1127.

C. Bay Area AQMD (BAAQMD) Regulation 2 Rule 10 (Rule 2-10)

BAAQMD Rule 2-10 is a permit rule. As such, it has fewer specifics about large 

CAFs than District Rule 4570, which is a prohibitory rule.
San Joaquin Valley Unified Air Pollution Control District September 18, 2014

A-12 Attachment A, Supplemental Documentation: Subpart 4 Requirements

2012 PM2.5 Plan and Rule 2201

Applicability/Exemption/Large CAF Definition

BAAQMD Rule 2-10 was adopted on July 19, 2006 and has not been amended. 

BAAQMD Rule 2-10 applies to large CAFs as defined by ARB. District Rule 

4570 defines large CAFs the same way except for large CAFs for horses. 

District Rule 4570 defines a large CAF for horses as having at least 3,000 head, 

whereas BAAQMD Rule 2-10 defines a large CAF for horses as having at least 

2,500 head. There are currently no CAFs in the San Joaquin Valley with the 

capacity to house at least 2,500 horses and no CAFs for horses in the San 

Joaquin Valley are expected to exceed this threshold in the foreseeable future.

In addition to applying to large CAFs, District Rule 4570 lowers the applicability 

thresholds for the following CAFs:

 Dairies – from 1,000 milk cows to 500 milk cows 

 Broilers/Ducks and Layers – from 650,000 birds to 400,000 birds

Therefore, Rule 4570 is more stringent regarding applicability.

Requirements for CAFs

The BAAQMD permit conditions must implement control measures that represent 

Reasonably Available Control Technology (RACT) to reduce emissions of VOC, 

NOx and PM from the facility. BAAQMD Rule 2-10 requires RACT mitigation 

measures rather than the more stringent BARCT controls required by District 

Rule 4570 as specifically noted in the BAAQMD staff report for their rule. District 

staff previously contacted BAAQMD staff and verified that there is no list of 

RACT mitigation measures in place should a large CAF apply for a permit. In 

this respect, District Rule 4570 is more stringent than BAAQMD Rule 2-10, 

especially considering that EPA has already determined that District Rule 4570 

satisfies RACT for VOC emissions. [26]

Testing, Monitoring, Recordkeeping Requirements

District Rule 4570 requires records to be maintained and retained for at least five 

years, whereas BAAQMD Rule 2-10 requires records to be retained for three 

years. District Rule 4570 therefore has a more stringent record retention 

requirement.

District Rule 4570 requires facilities not subject to the mitigation measure 

requirements to maintain sufficient records to demonstrate their exemption 

status. Facilities subject to the mitigation measure requirements must maintain 

 

26 United States Environmental Protection Agency, Region IX Air Division (August 2011). EPA's Analysis 

of San Joaquin Valley Unified Air Pollution Control District’s Rule 4570, Confined Animal Facilities. 

http://www.aqmd.gov/docs/default-source/Agendas/Governing-Board/2014/2014-jun6-031.pdf?sfvrsn=2
San Joaquin Valley Unified Air Pollution Control District September 18, 2014

A-13 Attachment A, Supplemental Documentation: Subpart 4 Requirements

2012 PM2.5 Plan and Rule 2201

sufficient records to demonstrate implementation of each mitigation measure 

selected. Facilities must also maintain animal population records. BAAQMD

Rule 2-10 requires the maintenance of animal population records but does not 

require specific records needed to demonstrate implementation of each 

mitigation measure selected. District Rule 4570 is therefore more stringent in the 

type of records that must be maintained.

Conclusion – Comparison with Bay Area AQMD Regulation 2 Rule 10

District Rule 4570 requires facilities to choose specific mitigation measures, 

makes several mitigation measures mandatory. In addition, District Rule 4570 

has lower applicability thresholds for dairies, chickens, and ducks. Based on this 

information and the discussion above, District Rule 4570 is far more stringent 

than BAAQMD Rule 2-10.

D. Ventura County APCD (VCAPCD) Rule 23 – Exemptions from Permit

In response to California Senate Bill (SB) 700, VCAPCD revised its “Exemptions 

from Permit” rule to remove an exemption for agricultural operations, including 

CAFs. VCAPCD does not have a specific rule for CAFs. In its staff report for the 

rule revision, VCAPCD staff noted that no facilities in their jurisdiction would meet 

the “large CAF” definition and there was no expectation that a large CAF would 

move into the area in the foreseeable future; therefore, no separate CAF rule 

was necessary.

Applicability/Exemption/Large CAF Definition

VCAPCD Rule 23 adopted ARB’s definition of large CAFs. District Rule 4570 

defines large CAFs the same way except for large CAFs for horses. District Rule 

4570 defines a large CAF for horses as having at least 3,000 head, whereas 

VCAPCD Rule 23 defines a large CAF for horses as having at least 2,500 head. 

There are currently no CAFs in the San Joaquin Valley with the capacity to house 

at least 2,500 horses and no CAFs for horses in the San Joaquin Valley are 

expected to exceed this threshold in the foreseeable future.

In addition to applying to large CAFs, District Rule 4570 lowers the applicability 

thresholds for the following CAFs:

 Dairies – from 1,000 milk cows to 500 milk cows 

 Broilers/Ducks and Layers – from 650,000 birds to 400,000 birds

Therefore, Rule 4570 is more stringent regarding applicability.

Requirements for CAFs

There are no facilities that would trigger the large CAF threshold within Ventura 

County, as stated in the Ventura County CAPCD staff report for amending Rule 
San Joaquin Valley Unified Air Pollution Control District September 18, 2014

A-14 Attachment A, Supplemental Documentation: Subpart 4 Requirements

2012 PM2.5 Plan and Rule 2201

23. The VCAPCD New Source Review Rule does not list mitigation measures 

for large CAFs. Instead, BACT would be triggered by a new CAF that met the 

“large CAF” definition or BACT would be triggered if an existing CAF expanded 

operations enough to meet the “large CAF” definition. At that point, VCAPCD

staff would determine BACT for the CAF.

Conclusion – Ventura County APCD Rule 23

Ventura County APCD does not have a specific rule for CAFs; therefore, District 

Rule 4570 is more stringent.

E. Sacramento Metropolitan AQMD (SMAQMD) Rule 496

Like District Rule 4570, Sac Metro AQMD Rule 496 is a prohibitory rule, meaning 

that there are detailed requirements for operators. 

Applicability/Exemption/Large CAF Definition

SMAQMD Rule 496 was adopted on August 24, 2006 and has not been 

amended. 

SMAQMD Rule 496 applies to large CAFs as defined by ARB. District Rule 4570 

defines large CAFs the same way except for large CAFs for horses. District Rule 

4570 defines a large CAF for horses as having at least 3,000 head, whereas 

SMAQMD Rule 496 defines a large CAF for horses as having at least 2,500 

head. There are currently no CAFs in the San Joaquin Valley with the capacity 

to house at least 2,500 horses and no CAFs for horses in the San Joaquin Valley 

are expected to exceed this threshold in the foreseeable future.

In addition to applying to large CAFs, District Rule 4570 lowers the applicability 

thresholds for the following CAFs:

 Dairies - 1,000 milk cows to 500 milk cows 

 Broilers/ducks and Layers – 650,000 – 400,000

Therefore, Rule 4570 is more stringent regarding applicability.

Requirements for Dairy CAFs

Feed Mitigation Measures

District Rule 4570 has seven mitigation measures for feed and two mitigation 

measures for silage. Operators must implement four mandatory feed mitigation 

measures and chose another one from a list of three, for a total of five mitigation 

measures required for feed. 
San Joaquin Valley Unified Air Pollution Control District September 18, 2014

A-15 Attachment A, Supplemental Documentation: Subpart 4 Requirements

2012 PM2.5 Plan and Rule 2201

SMAQMD Rule 496 has seven Class One mitigation measures for feed and two 

Class One mitigation measures for silage. Operators must implement four feed 

mitigation measures and one silage mitigation measure.

District Rule 4570 requires a total of five feed mitigation measures, excluding 

silage, which is greater than the four feed mitigation measures required by 

SMAQMD Rule 496. In addition, four of the five feed mitigation measures are 

mandatory in District Rule 4570. Therefore, District Rule 4570 is more stringent.

Milk Parlor Mitigation Measures

District Rule 4570 has one required milk parlor mitigation measure. SMAQMD

Rule 496 also only requires one mitigation measure for milk parlors. Since both 

rules only require the use of one mitigation measure, both rules will be 

considered identical for this category.

Freestall Mitigation Measures

District Rule 4570 has five freestall mitigation measures, two of which are 

mandatory. The facility is also required to choose one additional mitigation 

measure from the remaining three. SMAQMD Rule 496 has eight Class One 

mitigations measures and one Class Two mitigation measure from which facilities 

are required to implement at least two. 

Rule 4570 will be considered more stringent since it requires more mitigation 

measures.

Corral Mitigation Measures

District Rule 4570 has nine corral mitigation measures, six of which are 

mandatory. The facility is also required to choose one additional mitigation 

measure from the remaining three. SMAQMD Rule 496 has 15 Class One 

mitigation measures, which are all optional, and three Class Two mitigation 

measures, from which facilities are required to choose at least six. District Rule 

4570 requires one additional mitigation measure; therefore in this respect District 

Rule 4570 is more stringent. 

SMAQMD Rule 496 has one Class One mitigation measure (inspect water pipes 

and troughs and repair leaks) that require increased frequency in comparison to 

the corresponding District Rule 4570 measure. SMAQMD Rule 496 rule requires 

this measure to be carried out daily, whereas District Rule 4570 requires it to be 

carried out only once every seven days. Although, SMAQMD Rule 496 has a 

higher frequency for this measure, the difference in the emissions reductions 

from the two frequencies is not expected to be significant. In addition, as 

discussed earlier the frequency required by SMAQMD Rule 496 exceeds RACT 
San Joaquin Valley Unified Air Pollution Control District September 18, 2014

A-16 Attachment A, Supplemental Documentation: Subpart 4 Requirements

2012 PM2.5 Plan and Rule 2201

when compared to inspection leak requirements in other rules and regulations. 

Overall, District Rule 4570 is more stringent.

Solid Waste and Separated Solids Mitigation Measures

District Rule 4570 contains only two mitigation measures, from which operators 

are required to choose at least one. SMAQMD Rule 496 has five Class One 

mitigation measures and three Class Two mitigation measures, from which 

facilities are required to choose at least two. 

Available studies have indicated that NH3 emissions from stored solid waste and 

separated solids pile to be a very small fraction of total NH3 emissions at dairies. 

Since the NH3 emissions from solid manure account for a very small fraction of 

emissions from the overall dairy, there would not be a significant increase in NH3

emission reductions if more measures are required from this category.

Liquid Waste Mitigation Measures

District Rule 4570 has four mitigation measures mitigation measures, from which 

operators are required to choose at least one. SMAQMD Rule 496 has four 

Class One mitigation measures and four Class Two mitigation measures, from 

which facilities are required to choose at least one. Since only one measure is 

required, both rules are equivalent in this respect. 

Manure Land Application Mitigation Measures

District Rule 4570 has two mitigation measures required out of six measures. 

SMAQMD Rule 496 has six Class One mitigation measures, from which facilities 

are required to choose at least two. Since two mitigation measures are required, 

both rules are equivalent in this respect. 

Requirements for Poultry Large CAFs

There is a large degree of variability in the manure management practices, 

housing techniques, and potential feeding practices for the different type of 

poultry operations in the San Joaquin Valley. Due to these differences, District 

Rule 4570 separates poultry CAFs into the following categories: 1) layers and 2) 

broilers, ducks, and turkeys.

Although on the surface the poultry requirements results in fewer mitigation 

measures compared to the other rules, the segregating of the types of poultry 

has allowed the mitigation measures to be tailored specifically to the type of 

poultry operation. In addition, all measures for poultry in District Rule 4570 are 

now mandated rather than left as options. Due to this reconfiguration and taking 

into consideration the latest science, the District Rule 4570 requirements for 

poultry are more stringent than SMAQMD Rule 496.
San Joaquin Valley Unified Air Pollution Control District September 18, 2014

A-17 Attachment A, Supplemental Documentation: Subpart 4 Requirements

2012 PM2.5 Plan and Rule 2201

Other CAFs

In addition to dairy and poultry CAF mitigation measures discussed above, 

District Rule 4570 provides specific mitigation measure option tables for beef 

cattle feedlots, other cattle facilities, and swine facilities. SMAQMD Rule 496 

does not address mitigation measures for these additional CAF categories. For 

these types of large CAFs, District Rule 4570 is more stringent.

Requirements – Suspension and Substitution of Mitigation Measures

Both rules allow for substitution of one mitigation measure with an equivalent or 

more stringent measure with the submission of the appropriate application. 

District Rule 4570 also allows the temporary suspension of a mitigation measure 

upon the determination by a certified veterinarian or nutritionist that such a 

suspension is necessary for animal health purposes. The District must be 

notified within 48 hours, and a new measure must be implemented if the 

suspension is expected to last longer than 30 days. SMAQMD Rule 496 does 

not have a specific provision for temporary suspension of mitigation measures. 

As discussed above, District Rule 4570 is as stringent as SMAQMD Rule 496.

Testing, Monitoring, Recordkeeping Requirements

The testing, monitoring, and recordkeeping provisions of District Rule 4570 and 

SMAQMD Rule 496 are nearly identical and are of equal stringency.

Conclusion – Comparison with Sac Metro AQMD Rule 496

For dairy CAFs, District Rule 4570 is more stringent than SMAQMD Rule 496. 

District Rule 4570 requires emission reductions from four additional emission 

categories - milk parlors, feed, freestall barns, and liquid manure - that are not 

addressed by SMAQMD Rule 496 as well as having specific requirements for

other types of CAFs. District Rule 4570 also requires facilities to choose more 

mitigation measures and mandates several mitigation measures. In addition, 

Rule 4570 applies to dairies with greater than 500 milk cows and 400,000 layers 

and broilers while SMAQMD Rule 496 applies to dairies with 1,000 milk cows or 

more and broiler and layer operations with more than 650,000 birds. As shown 

in the discussion above, District Rule 4570 is more stringent than SMAQMD Rule 

496.

F. Imperial County APCD (ICAPCD) Rule 217 – Large Confined Animal 

Facilities Permits Required and ICAPCD Policy Number 38 – Recommended 

Mitigation Measures for Large Confined Animal Facilities 

Imperial County APCD Rule 217 is a permits rule. ICAPCD Rule 217 requires 

that owners or operators of large CAFs submit an emissions mitigation plan that 

demonstrates that the facility will use RACT to reduce emissions of pollutants that 
San Joaquin Valley Unified Air Pollution Control District September 18, 2014

A-18 Attachment A, Supplemental Documentation: Subpart 4 Requirements

2012 PM2.5 Plan and Rule 2201

contribute to the non-attainment of any ambient air quality standard and are within 

the ICAPCD’s regulatory authority.

ICAPCD Rule 217 requires operators of large CAFs to implement the control 

measures identified in their emissions mitigation plan, which may be selected from 

the ICAPCD Policy Number 38, Recommended Mitigation Measures for Large 

Confined Animal Facilities. ICAPCD Policy Number 38 specifies the number of 

mitigation measures the operator should implement for each operation within the 

CAF. The following discussion compares the recommended mitigation measures 

in ICAPCD Policy Number 38 to the measures in District Rule 4570. However, 

since the mitigation measures in ICAPCD Policy Number 38 are only 

recommended by ICAPCD Rule 217 rather than being explicitly required, it is 

clear that District Rule 4570 is more stringent.

Applicability/Exemption/Large CAF Definition

Imperial County Rule 217 was adopted on October 10, 2006 and has since not 

been amended. 

ICAPCD adopted ARB’s definition of large CAF. District Rule 4570 defines large 

CAFs the same way except for large CAFs for horses. District Rule 4570 defines 

a large CAF for horses as having at least 3,000 head, whereas ICAPCD Rule 

217 defines a large CAF for horses as having at least 2,500 head. There are 

currently no CAFs in the San Joaquin Valley with the capacity to house at least 

2,500 horses and no CAFs for horses in the San Joaquin Valley are expected to 

exceed this threshold in the foreseeable future.

In addition to applying to large CAFs, District Rule 4570 lowers the applicability 

thresholds for the following CAFs:

 Dairies – from 1,000 milk cows to 500 milk cows 

 Broilers/Ducks and Layers – from 650,000 birds to 400,000 birds

ICAPCD Policy Number 38 only lists mitigation measures for dairy operations and 

beef feedlot operations while District Rule 4570 covers additional CAFs (swine, 

chicken layer, chicken broiler, duck and turkey, and other CAFs). Therefore, 

more CAFs are subject to the requirements of District Rule 4570 than ICAPCD 

Rule 217. 

Therefore, Rule 4570 is more stringent regarding applicability.

Requirements for Dairy CAFs

Milk Parlor Mitigation Measures
San Joaquin Valley Unified Air Pollution Control District September 18, 2014

A-19 Attachment A, Supplemental Documentation: Subpart 4 Requirements

2012 PM2.5 Plan and Rule 2201

ICAPCD Policy Number 38 has only one mitigation measure for the milk parlor. 

The District rule also only has one mitigation measure. Since the mitigation 

measure is identical, both rules are identical under this section.

Freestall Mitigation Measures

District Rule 4570 has five freestall mitigation measures, two of which are 

mandatory. The facility is also required to choose one additional mitigation 

measure from the remaining three. ICAPCD Policy Number 38 has eight 

mitigation measures, from which operators are required to choose at least two. 

Since District Rule 4570, requires three mitigation measures and mandates two 

out of the three, District Rule 4570 is more stringent than ICAPCD Policy Number 

38.

Corral Mitigation Measures

District Rule 4570 has nine mitigation measures, six of which are mandatory. 

The facility is also required to choose one additional mitigation measure from the 

remaining three. ICAPCD Policy Number 38 has eight mitigation measures, from 

which facilities are required to choose at least four.

For three of the mitigation measures, the compliance times differ between the 

District rule and ICAPCD Policy Number 38. For these measures, ICAPCD 

Policy Number 38 allows longer time periods between repeated performance of 

the measures than District Rule 4570. For these three mitigation measures, 

District Rule 4570 is more stringent because District Rule 4570 requires repeated 

performance of the otherwise identical mitigation measures in shorter time 

periods.

For two of the mitigation measures, the maximum depth of manure differs 

significantly between the District Rule 4570 and ICAPCD Policy Number 38. For 

these measures, ICAPCD Policy Number 38 allows manure depths that are 

deeper than allowed by District Rule 4570. For these two mitigation measures, 

District Rule 4570 rule is more stringent because the District Rule 4570 requires

shallower manure depths for otherwise identical mitigation measures. 

Therefore, District Rule 4570 is far more stringent than the ICAPCD Policy 

Number 38.

Solid Waste and Separated Solids Mitigation Measures

District Rule 4570 has two solid waste and separated solids mitigation measures, 

from which operators are required to choose at least one. ICAPCD Policy 

Number 38 has four mitigation measures from which facilities are required to 

choose at least one. Therefore, both rules are identical in this category.
San Joaquin Valley Unified Air Pollution Control District September 18, 2014

A-20 Attachment A, Supplemental Documentation: Subpart 4 Requirements

2012 PM2.5 Plan and Rule 2201

There are a few differences in ICAPCD Policy Number 38 mitigation measures 

when compared to District Rule 4570. ICAPCD Policy Number 38 policy requires 

that manure piles are covered year round whereas District Rule 4570 requires 

that the piles be covered from October through May – the months the months in 

the San Joaquin Valley in which rainfall is most likely. However, because of the 

greater depth of manure allowed in corrals and increased duration (up to two 

years) for removal of manure from the corrals allowed by ICAPCD Policy Number 

38, CAFs in the ICAPCD are able to allow manure to accumulate in the corrals 

until it can be hauled offsite. Few, if any, CAFs in the ICAPCD are expected to 

actually store manure onsite outside of corrals, so it is likely than no facilities in 

ICAPCD are actually choosing and implementing this measure. Separated solids 

piles are not specifically addressed in ICAPCD Policy Number 38. Overall 

District Rule 4570 is as stringent as ICAPCD Policy Number 38.

Liquid Waste Mitigation Measures

District Rule 4570 has four liquid waste mitigation measures mitigation 

measures, from which operators are required to choose at least one. ICAPCD 

Policy Number 38 has four mitigation measures, from which operators are 

required to choose at least one. ICAPCD Policy Number 38 contains an option 

to manage the facility so that lagoons only contain waste from milking parlor and 

storm water as a mitigation measure. District Rule 4570 does not contain this 

option. This difference, although worth noting, is not expected to influence the 

overall effectiveness of District Rule 4570 and District Rule 4570 is as stringent 

as ICAPCD Policy Number 38.

Manure Land Application Mitigation Measures

District Rule 4570 has two mitigation measures that are mandatory if applicable. 

Imperial County APCD policy has a menu of five mitigation measures from which 

operators are required to choose two. Since two measures are required by both 

ICAPCD Policy Number 38 and District Rule 4570, they will be considered 

identical under this category. 

Requirements for Beef Feedlot CAFs

Animal Housing Mitigation Measures

District Rule 4570 has nine mitigation measures, six of which are mandatory. 

The facility is also required to choose one additional mitigation measure from the 

remaining three. ICAPCD Policy Number 38 has nine mitigation measures, from 

which facilities are required to choose at least four. Since operators in Imperial 

County are required to implement fewer mitigation measures, District Rule 4570 

is more stringent.
San Joaquin Valley Unified Air Pollution Control District September 18, 2014

A-21 Attachment A, Supplemental Documentation: Subpart 4 Requirements

2012 PM2.5 Plan and Rule 2201

For three of the mitigation measures, the compliance times differ between the 

District rule and ICAPCD Policy Number 38. For these measures, ICAPCD 

Policy Number 38 allows longer time periods between repeated performances of 

the measures than District Rule 4570. For these three mitigation measures, the 

District rule is more stringent because the District Rule 4570 requires repeated 

performance of the otherwise identical mitigation measures in shorter time 

periods.

For two of the mitigation measures, the maximum depth of manure differs 

significantly between the District Rule 4570 and ICAPCD Policy Number 38. For 

these measures, ICAPCD Policy Number 38 allows manure depths that are 

deeper than allowed by District Rule 4570. For these two mitigation measures, 

District Rule 4570 rule is more stringent because the District Rule 4570 requires

shallower manure depths for otherwise identical mitigation measures. 

Solid Waste and Separated Solids Mitigation Measures

District Rule 4570 has two solid waste and separated solids mitigation measures, 

from which operators are required to choose at least one. ICAPCD Policy 

Number 38 has four mitigation measures from which facilities are required to 

choose at least one. Therefore, both rules are identical in this category.

ICAPCD Policy Number 38 policy requires that manure piles are covered year 

round whereas District Rule 4570 requires that the piles be covered from October 

through May – the months the months in the San Joaquin Valley in which rainfall 

is most likely. However, because of the greater depth of manure allowed in 

corrals and increased duration (up to two years) for removal of manure from the 

corrals allowed by ICAPCD Policy Number 38, CAFs in the ICAPCD are able to 

allow manure to accumulate in the corrals until it can be hauled offsite. Few, if 

any, CAFs in the ICAPCD are expected to actually store manure onsite outside 

of corrals, so it is likely than no facilities in ICAPCD are actually choosing and 

implementing this measure. Overall District Rule 4570 is as stringent as ICAPCD 

Policy Number 38.

Liquid Manure Handling

ICAPCD Policy Number 38 does not address liquid manure handling for beef 

feedlot operations. This is likely because beef feedlot facilities in ICAPCD do not 

generally use liquid manure management systems. District Rule 4570 requires 

one measure to be selected out of a menu of options, if applicable. Therefore, 

Rule 4570 is more stringent in this category.

Manure Land Application Mitigation Measures

District Rule 4570 has two mitigation measures that are mandatory if applicable. 

ICAPCD Policy 38 has a menu of five mitigation measures from which operators 
San Joaquin Valley Unified Air Pollution Control District September 18, 2014

A-22 Attachment A, Supplemental Documentation: Subpart 4 Requirements

2012 PM2.5 Plan and Rule 2201

are required to choose two. Since two measures are required by both ICAPCD 

Policy Number 38 and District Rule 4570, they will be considered identical under 

this category. 

Requirements for Other CAFs

In the same manner as for dairy and beef feedlot operations, District Rule 4570 

specifies mitigation methods for confined animal facilities other than dairies and 

beef feedlots. ICAPCD Policy 38 only has mitigation measures for dairy and beef 

feedlot operations. In comparing the two documents, District Rule 4570 is 

therefore more comprehensive and stringent.

Requirements – Suspension and Substitution of Mitigation Measures

District Rule 4570 and ICAPCD Policy 38 allow for substitution of one mitigation 

measure with an equivalent or more stringent one with the submission of the 

appropriate application. District Rule 4570 also allows the temporary suspension 

of a mitigation measure upon the determination by a certified veterinarian or 

nutritionist that such a suspension is necessary for animal health purposes. The 

District must be notified within 48 hours, and a new measure must be 

implemented if the suspension is expected to last longer than 30 days. ICAPCD 

Policy 38 allows for temporary suspension of mitigation measures under 

circumstances similar to District Rule 4570. Based on the discussion, Rule 4570 

is as stringent as ICAPCD Policy 38.

Testing, Monitoring, Recordkeeping Requirements

District Rule 4570 requires records to be maintained and retained for at least five 

years, whereas ICAPCD Rule 217 requires records to be retained for two years. 

District Rule 4570 therefore has a more stringent record retention requirement.

District Rule 4570 requires facilities not subject to the mitigation measure 

requirements to maintain sufficient records to demonstrate their exemption 

status. Facilities subject to the mitigation measure requirements must maintain 

sufficient records to demonstrate implementation of each mitigation measure 

selected. Facilities must also maintain animal population records. ICAPCD Rule 

217 requires the maintenance of animal population records but does not require 

specific records needed to demonstrate implementation of each mitigation 

measure selected. District Rule 4570 is therefore more stringent in the type of 

records required to be maintained.

Conclusion – Comparison with Imperial County APCD Rule 217 and Imperial 

County APCD Policy Number 38

ICAPCD Rule 217 requires operators of large CAFs to implement the control 

measures identified in their emissions mitigation plan, which may be selected from 

the ICAPCD Policy Number 38, Recommended Mitigation Measures for Large 
San Joaquin Valley Unified Air Pollution Control District September 18, 2014

A-23 Attachment A, Supplemental Documentation: Subpart 4 Requirements

2012 PM2.5 Plan and Rule 2201

Confined Animal Facilities; however, compliance with ICAPCD Policy Number 38 is 

not explicitly required by the rule. District Rule 4570 contains several mandatory 

mitigation measures, unlike the optional nature of the mitigation measures in 

Imperial County APCD Rule 217. District Rule 4570 also has a lower 

applicability threshold for dairies (500 milk cows). In addition, ICAPCD Policy 

Number 38 only lists mitigation measures for dairy operations and beef feedlot 

operations while District Rule 4570 covers additional CAFs (swine, chicken layer, 

chicken broiler, duck and turkey, and other CAFs). As shown the discussion 

above, District Rule 4570 is far more stringent than ICAPCD Rule 217 and 

ICAPCD Policy Number 38.

G. Butte County AQMD (BCAQMD) Rule 450 – Large Confined Animal 

Facilities

Butte County AQMD Rule 450 is a permits rule. It outlines, in general terms, the 

requirements for a complete permit application and how the staff would evaluate 

and approve/disapprove the permit application.

Applicability/Exemption/Large CAF Definition

Butte County AQMD Rule 450 was adopted on December 21, 2006 and has 

since not been amended. 

BCAQMD adopted ARB’s definition of large CAF. District Rule 4570 defines 

large CAFs the same way except for large CAFs for horses. District Rule 4570 

defines a large CAF for horses as having at least 3,000 head, whereas BCAQMD

Rule 450 defines a large CAF for horses as having at least 2,500 head. There 

are currently no CAFs in the San Joaquin Valley with the capacity to house at 

least 2,500 horses and no CAFs for horses in the San Joaquin Valley are 

expected to exceed this threshold in the foreseeable future.

In addition to applying to large CAFs, District Rule 4570 lowers the applicability 

thresholds for the following CAFs:

 Dairies – from 1,000 milk cows to 500 milk cows 

 Broilers/Ducks and Layers – from 650,000 birds to 400,000 birds

Therefore, Rule 4570 is more stringent regarding applicability.

CAF Requirements

BCAQMD Rule 450 requires large CAFs to obtain a permit and to submit and 

implement a mitigation plan; however, the rule does not list mitigation measures

or specify the number of mitigation measures required. District Rule 4570 has a 

menu of specific mitigation measures and stipulates the number of mitigation 

measures an operator is required to implement. In this regard, District Rule 4570 

is more stringent than the BCAQMD Rule 450.
San Joaquin Valley Unified Air Pollution Control District September 18, 2014

A-24 Attachment A, Supplemental Documentation: Subpart 4 Requirements

2012 PM2.5 Plan and Rule 2201

Testing, Records, and Reporting Requirements

BCAQMD Rule 450 requires that all CAFs record the daily number of animals onsite. These records are to be kept on-site for two years and presented if 

requested. District Rule 4570 requires testing and records be kept to 

demonstrate compliance with the operator’s selected mitigation measures. The 

records are to be kept for five years and presented upon the request of EPA or 

the District. Because District Rule 4570 covers testing, as well as having a 

longer record retention time, it is more stringent than BCAQMD Rule 450.

Conclusion – Comparison with Butte County AQMD Rule 450

District Rule 4570 contains specifies the actual mitigation measures that facilities 

are required to implement. In addition, District Rule 4570 has lower applicability 

thresholds for dairies, chicken facilities, and duck facilities. As shown in the 

discussion above, District Rule 4570 is more stringent than BCAQMD Rule 450.

H. Idaho Administrative Procedure Act (IDAPA) 58.01.01 Sections 760-764: 

Rules for the Control of Ammonia from Dairy Farms

Applicability/Exemption

IDAPA 58.01.01 Sections 760-763 was adopted on March 30, 2007 and IDAPA 

58.01.01 Subsection 764.02: Table – Ammonia Control Practices for Idaho 

Dairies was last amended on May 8, 2009. 

Pursuant to IDAPA 58.01.01 Section 761, Sections 760-764 apply to dairies of 

the following sizes. The thresholds are based on estimating the number of cattle 

required to produce 100 ton of ammonia annually. Different thresholds are given 

for drylot dairies, dairies with scraped freestalls, and dairies with flushed 

freestalls. The thresholds are given on the basis of Animal Units (AU) (1,000 lbs 

of live weight) and on a mature cow equivalent basis (1,400 lbs of live weight).

SUMMARY: Animal Unit (AU) or mature cow threshold to produce 100 ton 

NH3/year

Animal Unit (AU) Basis Drylot Free Stall/Scrape Free Stall/Flush

AU (100 t NH3) Threshold

No land app 7,089 3,893

27% volatilization 2,293 16,842 3,827

80% volatilization26,397 3,700

Total Cows (100 t NH3) Threshold

Cow Basis (1,400 lb) Drylot Free Stall/Scrape Free Stall/Flush

No land app 5,063 2,781 1,638
San Joaquin Valley Unified Air Pollution Control District September 18, 2014

A-25 Attachment A, Supplemental Documentation: Subpart 4 Requirements

2012 PM2.5 Plan and Rule 2201

27% volatilization14,887 2,733

80% volatilization24,589 2,643

No land app 5,063 2,781

1 Assumes expected level of N->NH3 volatilization for drop-hose or ground level liquid manure application.

2 Assumes expected level of N->NH3 volatilization for center pivot or other conventional sprinkler irrigation liquid manure 

application

The smallest dairy to which IDAPA 58.01.01 Sections 760-764 applies would 

have the equivalent of at least 1,638 mature cows in flushed freestalls and a 

larger number of animals in scraped freestalls or corrals. In comparison, District 

Rule 4570 applies to dairy CAFs with at least 500 milking cows (at least 700 AU 

or 500 mature cows). In addition, District Rule 4570 applies to other types of 

confined animal facilities, including beef cattle feedlots, other cattle facilities, 

poultry facilities, and swine facilities. Therefore, District Rule 4570 is more 

stringent regarding applicability.

Requirements for Dairies 

Each dairy farm subject to IDAPA 58.01.01 Sections 760 - 764 must employ Best 

Management Practices (BMPs) for the control of ammonia. The BMPs are 

applied to the following systems at a dairy: Waste Storage and Treatment 

Systems, General Practices, Freestall Barns, Open Lots and Corrals, Animal 

Nutrition, Composting Practices, and Land Application. A total of twenty-seven 

(27) points must be achieved for the BMPs employed. The table located in 

Subsection 764.02 lists the approved BMPs and their associated point values. 

During development of the regulation, a point system with a maximum of 20 

points was assigned to each practice. A practice receiving 20 points equates to 

a system or practice that is considered to result in major reduction in ammonia 

emissions for that specific process. However, according to the supporting 

documentation, this point system is “arbitrary”. [27]Therefore, there is no direct 

correlation from the points required and the amount of emission reductions 

achieved. In fact, due to the flexibility allowed in this rule, even if all points have 

been met by the rule and depending on which mitigation measures are selected, 

the overall ammonia emission reductions may not be substantial. The Idaho 

Department of Environmental Quality (DEQ) may also determine a practice not 

listed in the table constitutes a BMP and assign a point value. Points may also 

be obtained through third party export with sufficient documentation. 

The paper Commentary: Ammonia-Based Air Quality Permits for Idaho Dairies[28]

indicated that “Solid separation of manure, corral harrowing, low-pressure 

 

[27]

Idaho Department of Environmental Quality (2006). Scientific Basis for the Control of Ammonia from 

Dairy Farms Best Management Practices 7/18/2006 by Ron E. Sheffield, Waste Management Engineer, 

University of Idaho and Bruce Louks, Air Quality Division, Idaho Department of Environmental Quality. 

http://www.deq.idaho.gov/media/635665-58_0101_0502_scientific_basis_final.pdf

[28]

Sheffield, R. E. and Louks, B. (2008). COMMENTARY: Ammonia-Based Air Quality Permits for Idaho 

Dairies. Environmental Practice, 10, pp 13-19. doi:10.1017/S1466046608080046.

http://journals.cambridge.org/action/displayAbstract?fromPage=online&aid=1888928
San Joaquin Valley Unified Air Pollution Control District September 18, 2014

A-26 Attachment A, Supplemental Documentation: Subpart 4 Requirements

2012 PM2.5 Plan and Rule 2201

irrigation, composting, and rapid manure removal from outdoor lots were found to 

be the most common BMPs.” 

Solids Separation

In the Idaho regulation, solids separation refers to “gravity or mechanical 

separation system to remove manure solids from liquid waste stream.” This 

practice has been implemented by almost all dairies in the San Joaquin Valley 

subject to District Rule 4570 to comply with the liquid manure mitigation measure

requirements of District Rule 4570. 

Corral Harrowing/Cleaning

In the Idaho regulation corral harrowing refers to harrowing to distribute 

deposited manure, reshape corral surface, and/or remove manure from corral 

surface and rapid manure removal from outdoor lots refers to the removal of 

winter time manure and corral bedding from open lot surface in spring or as 

quickly as practicable. District Rule 4570 has much more stringent requirements 

for corral cleaning and maintenance at dairies. For corrals, District Rule 4570 

requires dairies to implement the following measures: a) Cleaning manure from 

corrals at least four times per year with at least 60 days between cleaning or b) 

cleaning corrals at least once between April and July and at least once between

September and December; and a) Scraping, vacuuming, or flushing concrete lanes 

in corrals at least once every day for mature cows and every seven days for support 

stock, or b) Cleaning concrete lanes such that the depth of manure does not exceed 

twelve inches at any point or time; and inspection of water pipes and troughs and 

repairing leaks at least once every seven days; and a) Sloping the surface of the 

corrals at least 3% where the available space for each animal is 400 square feet or 

less and Sloping the surface of the corrals at least 1.5% where the available space 

for each animal is more than 400 square feet per animal, or b) Maintaining corrals to 

ensure proper drainage preventing water from standing more than forty-eight (48) 

hours, or c) Harrowing, raking, or scraping corrals sufficiently to maintain a dry 

surface. In addition, District Rule 4570 requires dairies to choose an additional 

corral mitigation measure, requiring corrals to be managed such that the manure 

depth in the corral does not exceed twelve inches at any time or point, except for incorral mounding. Therefore, the corral cleaning and maintenance requirements of 

District Rule 4570 are far more stringent than IDAPA 58.01.01 Sections 760 – 764. 

Previous emission studies conducted in the San Joaquin Valley have 

demonstrated that the corrals and pens are the sources with the greatest 

potential for NH3 emissions on San Joaquin Valley dairies[29]and, therefore, the 

much more stringent corral cleaning and maintenance measures required by 

District Rule 4570 have the potential for far greater NH3 reductions.

 

[29]

See: Schmidt, C. and Card, T. (2006) Dairy Air Emissions Report: Summary of Dairy Emission 

Estimation Procedures (May 2006). Final Report to California Air Resource Board (ARB). 

http://www.arb.ca.gov/ag/caf/SchmidtDairyEmissions2005.pdf

http://www.arb.ca.gov/ag/caf/SchmidtDairyTestData2005.pdf
San Joaquin Valley Unified Air Pollution Control District September 18, 2014

A-27 Attachment A, Supplemental Documentation: Subpart 4 Requirements

2012 PM2.5 Plan and Rule 2201

Liquid Manure Application

In the Idaho regulation, Low Energy/Pressure Application Systems refers to use 

of center pivot and liner-move irrigation strategy that applies liquids at low 

pressures using drop nozzles. The guidance for the regulation states that larger 

droplets result in lower emissions but may cause infiltration problems on some 

soils. The use of center pivot and liner-move irrigation to apply liquid manure is 

very uncommon in the San Joaquin Valley and may be prohibited in the use 

permits for many dairies. In the San Joaquin Valley it is much more common to 

apply liquid manure to cropland through flood or furrow irrigation after it has been 

diluted with fresh irrigation water as generally required by either the Water 

Quality Board or the local County and as a means to avoid damage to growing 

crops. Because of the reduced surface area, flood and furrow irrigation have

even lower emissions than low pressure sprinkler irrigation systems. Dilution of 

the liquid manure with fresh irrigation water further reduces NH3 emissions and 

is also listed as a BMP in the Idaho regulation. Therefore, the liquid manure 

practices utilized in the San Joaquin Valley are more stringent than the Idaho 

regulation.

Composting

In the Idaho regulation “composting” refers to stacking and drying of separated 

manure solids or corral manure. Almost all dairies in the San Joaquin Valley 

utilize this practice to prepare solid manure and/or separated solids for bedding 

and/or for use on cropland. In addition, District Rule 4570 requires that dairies 

implement one of the following measures for solid manure or separated solids: 1) 

within 72 hours of removal from housing, either: a) Remove dry manure from the 

facility, or b) Cover dry manure outside the housing with a weatherproof covering 

from October through May, except for times when wind events remove the covering, 

not to exceed 24 hours per event; or 2) Within seventy-two hours of removal from 

the drying process, either: a) Remove separated solids from the facility, or b) Cover 

separated solids outside the housing with a weatherproof covering from October 

through May, except for times when wind events remove the covering, not to exceed 

twenty-four 24 hours per event. Therefore, the general management practices

conducted on dairies in the San Joaquin Valley and the requirements of District Rule 

4570 are far more stringent than the Idaho regulation. 

For dairy corrals, which are the largest source of NH3 emissions at dairies in the 

San Joaquin Valley, District Rule 4570 requires more stringent mitigation

measures and a greater number of these measures. District Rule 4570 is also 

more specific in regards to mitigation measures required from other processes at 

dairies and the number of mitigation measures that must be implemented for 

each process; as a result, District Rule 4570 is able to better target the reduction 

of emissions from these different operations. Therefore, District Rule 4570 is 

more stringent than IDAPA 58.01.01 Sections 760 - 764.

Requirements for Other Confined Animal Facilities

As stated above, District Rule 4570 provides specific mitigation measures for 
San Joaquin Valley Unified Air Pollution Control District September 18, 2014

A-28 Attachment A, Supplemental Documentation: Subpart 4 Requirements

2012 PM2.5 Plan and Rule 2201

beef cattle feedlots, other cattle facilities, poultry facilities, and swine facilities. 

IDAPA 58.01.01 Sections 760-764 does not address mitigation measures for 

these additional categories. Therefore, District Rule 4570 is more stringent for 

this category.

Requirements – Suspension and Substitution of Mitigation Measures

IDAPA 58.01.01 Subsection 762.03 provides that if a dairy farm not subject to 

Sections 760 - 764 would become subject to these regulations as a result of an 

emergency (for example if a dairy farmer takes additional cows due to 

unforeseen circumstances), the dairy farm must notify the Idaho Department of 

Environmental Quality (DEQ) in writing within 14 days explaining the emergency 

circumstances. The dairy farm would be exempt from these requirements for up 

to one year as long as the consequences of the emergency continue. In the 

event of unforeseen equipment upsets and breakdowns, so long as corrective 

action is taken within a reasonable time, the event does not reduce the BMP 

point value.

In comparison, District Rule 4570 allows an operator to temporarily suspend any 

mitigation measure as long as the suspension is recommended by a licensed 

veterinarian or animal nutritionist on the basis of animal health. The operator 

must notify the District within 48 hours prior to the suspension. If the suspension 

is expected to last longer than 30 days, then the operator must submit a new 

mitigation plan that identifies a new mitigation measure to be implemented in 

place of the suspended one.

District Rule 4570’s exemption under this category is much more stringent 

because it is a temporary suspension that cannot exceed 30 days, whereas the 

IDAPA 58.01.01 Sections 760-764 exemption may last much longer, without any 

requirement to substitute another measure. 

Therefore, in this category of mitigation measure suspensions/substitutions, 

District Rule 4570 is more stringent than IDAPA 58.01.01 Sections 760-764. 

Testing, Monitoring, Recordkeeping Requirements

Compliance with the requirements of IDAPA 58.01.01 Sections 760-764 is 

primarily determined by inspections by the Idaho State Department of 

Agriculture. The Idaho regulations do not specify what records must be kept or 

have any requirement that the records be maintained for a certain period of time.

District Rule 4570 includes specific requirements for monitoring, source testing 

as appropriate and recordkeeping to ensure mitigation measure are being 

implemented. Facilities must also maintain animal population records. District 

Rule 4570 also requires facilities not subject to the mitigation measure 

requirements to maintain sufficient records to demonstrate their exemption 
San Joaquin Valley Unified Air Pollution Control District September 18, 2014

A-29 Attachment A, Supplemental Documentation: Subpart 4 Requirements

2012 PM2.5 Plan and Rule 2201

status. District Rule 4570 requires records be retained for five years for all 

sources. District Rule 4570 is therefore more stringent in this area.

Conclusion – Comparison with IDAPA 58.01.01 Sections 760 - 764

For dairy facilities, District Rule 4570 is far more stringent than IDAPA 58.01.01 

Sections 760-764. Unlike IDAPA 58.01.01 Sections 760-764, District Rule 4570 

requires specific practices for the various operations at dairies. District Rule 

4570 also provides specific mitigation measures for beef cattle feedlots, other 

cattle facilities, poultry facilities, and swine facilities, while IDAPA 58.01.01 

Sections 760-764 does not. The measures required by the Idaho regulation are 

also based on an arbitrary point system and as such do not guarantee a specific 

degree of control. District Rule 4570 is, therefore, more stringent than IDAPA 

58.01.01 Sections 760-764.

IV. Conclusion:

After careful evaluation of federal rules and regulations as well as prohibitory rules in 

other areas, District staff concludes that District Rule 4570 satisfies RACT for NH3 

emissions from Confined Animal Facilities. This conclusion is supported by the fact that

EPA previously determined that District Rule 4570 satisfied RACT for VOC emissions 

from Confined Animal Facilities and many of the same measures will also limit NH3 

emissions from these facilities. The District also evaluated the feasibility of additional 

ammonia emissions reductions. However, the District has not identified any additional 

reasonable measures. In fact, the South Coast Air Quality Management District 

recently identified District Rule 4570 as the most stringent rule for this source category 

in their ozone Reasonably Available Control Technology Demonstration.30

A.2 Agricultural Fertilizers

Farms have continued to improve methods of fertilizer application over the years to 

maximize nitrogen use efficiency and minimize environmental impacts. Best 

management practices are being implemented to minimize nitrate leaching in irrigated 

crop production. Researchers at UC Cooperative Extension have been studying the 

nitrogen use efficiency for various crop types and have begun identifying the point at 

which the application of additional nitrogen no longer significantly increases crop quality 

and yields. This will allow growers to apply fertilizer with more precision to reduce the 

amount of nitrogen left in the soil.

Agricultural operations in California are regulated by the State Water Resources Control 

Board, which is charged by the state Legislature in enforcing state and federal water 

quality protection laws. The State Water Resources Control Board consists of Regional 

 

30 South Coast Air Quality Management District (June 6, 2014). Reasonably Available Control Technology 

Demonstration. http://www.aqmd.gov/docs/default-source/Agendas/Governing-Board/2014/2014-jun6-

031.pdf?sfvrsn=2
San Joaquin Valley Unified Air Pollution Control District September 18, 2014

A-30 Attachment A, Supplemental Documentation: Subpart 4 Requirements

2012 PM2.5 Plan and Rule 2201

Water Quality Control Boards (Regional Boards) that develop objectives and plans to 

protect the beneficial uses of water, recognizing local differences in climate, topography, 

geology and hydrology. All dairy farms in California’s Central Valley are regulated by 

the Central Valley Regional Water Quality Control Board (“Regional Board”). The vast 

majority of dairies - about 1,200 dairies are regulated under a Regional Board General 

Order31 and the remainder are regulated via individual orders that ensure compliance 

with the same requirements. These requirements include:

 A Nutrient Management Plan (NMP), prepared by a certified professional crop 

advisor or equivalent, designed to control nutrient losses for protection of surface 

water and groundwater;

 A Waste Management Plan (WMP), prepared by a licensed engineer;

 Environmental sampling and monitoring of soil, manure, water and plant tissue 

for compliance;

 Routine site inspections, record-keeping, and reporting; and

 Additional groundwater monitoring to assess ongoing water quality protection

A major purpose of these regulations is to ensure responsible storage and use of 

manure as an important crop fertilizer and soil builder, thus preventing unnecessary 

runoff or leaching of nitrogen compounds to the environment, where they can impact 

water quality. The NMP is designed to assure that the amount of nitrogen excreted by 

milking cows and support stock is in reasonable balance with the needs of crops grown 

at the dairy farm. Manure nitrogen in excess of crop needs should be exported off the 

farm to where it can be used by other farmers. Nitrogen used on the farm is required to 

be stored safely until it is used (the major purpose of the WMP) and then only applied to 

agricultural fields when needed for crop growth and in the amounts needed. Overapplication or mistimed application of nitrogen fertilizers can result in unnecessary 

losses of nitrogen to the environment, both as seepage below the root zone (in the form 

of nitrate or other nitrogen compounds)32 or as air emissions of ammonia gas, 

ammonium, and oxides of nitrogen.

The University of California suggested in 2005 that “... optimal N loading rates of 1.4 to 

1.65 times the crop N harvest removal are practical and, based on field observations, 

achievable if the production field is properly managed.”33 The UC assessment was the 

ultimate basis for performance standards set by the Regional Board in the General 

Order, which was adopted in 2007 and revised and re-issued in 2013. 

Research suggests that to achieve the more stringent targets in the General Order, 

many dairies had to greatly increase the precision of their manure and fertilizer 

applications, while also reducing the overall amount of nitrogen applied to their crops 

compared to plant uptake.34 On a group of San Joaquin Valley dairy farms, it was 

estimated that prior to adoption of the General Order in 2007, losses of nitrogen to 

groundwater alone ranged from 370 to 570 pounds per acre compared to 500 pounds of 

 

31 http://www.waterboards.ca.gov/centralvalley/board_decisions/adopted_orders/general_orders/r5-2013-0122.pdf

32See “Managing Dairy Manure in the Central Valley of California,” published by the University of California 

Committee of Experts on Dairy Manure Management, 2005. http://groundwater.ucdavis.edu/files/136450.pdf

33Ibid., p. 47

34“Cow Numbers and Water Quality – is there a magic limit?” (Harter, Menke 2005), 

http://groundwater.ucdavis.edu/files/136451.pdf
San Joaquin Valley Unified Air Pollution Control District September 18, 2014

A-31 Attachment A, Supplemental Documentation: Subpart 4 Requirements

2012 PM2.5 Plan and Rule 2201

uptake by crops.35 Similar or larger amounts of nitrogen are expected to volatilize to the 

atmosphere as ammonia and other compounds following excretion of manure from 

animals, during storage of manure in ponds or corrals, and in the process of applying 

manure to soil as a crop nutrient.36 Thus, as a result of full implementation of the 

General Order, losses of nitrates to groundwater on dairies may be reduced by up to 85 

percent compared to pre-General Order conditions, though this number will be smaller 

for dairies where manure was managed more precisely prior to the General Order’s 

adoption. 

Increasing crop nutrient uptake is also expected to reduce air emissions by providing for 

application of less excess fertilizer to crops, and therefore, less opportunity for 

volatilization in the fields. Some research already conducted found lower emissions with 

moderate nitrogen applications and suggested “synchronizing N applications with crop 

N demand. Once the N requirement for each crop stage is known, the N applications 

can be adjusted accordingly. This strategy should lead to improved N use efficiency and 

likely lower N2O emissions.”37

Other nitrogen compounds such as ammonia can also volatilize to air during application 

to fields. The University of California Committee of Experts on Dairy Manure 

Management has suggested that during application of manure water to crops, 

significant ammonia emissions can occur when manure water is not properly diluted (to 

below 100 ppm NH3/N) or applied during early growth of the crop. However, “in systems 

with frequent, but well diluted manure water applications, ammonia losses from the 

ground surface will commonly be minimal during the irrigation (10% or less).”38

Although additional research will be helpful in quantifying the environmental benefits of 

improved waste management and nutrient applications, the weight of evidence 

suggests that managing nutrient applications to fields as prescribed in the General 

Order, especially compared to pre-General Order management on some dairy farms, 

has significantly reduced losses of nitrogen compounds to the environment, including 

leaching of nitrogen compounds to groundwater and air emissions such as ammonia 

and nitrous oxide. 

A.3 Organic Material Composting (District Rule 4566)

I. District Rule Description:

District Rule 4566 (Organic Material Composting) is the most stringent rule in the nation 

for controlling emissions from composting operations; additional controls are

infeasible. Additionally, as discussed in Chapter 7 of the 2012 PM2.5 Plan, one of the 

technology focus areas for the District’s Technology Advancement Program is for waste 

 

35Ibid., Harter.

36Ibid., “Managing Dairy Manure in the Central Valley of California.”

37“Assessment of Nitrous Oxide Emissions in California’s Dairy Systems, DRAFT FINAL REPORT, California Air 

Resources Board, Contract No. 09-325, William R. Horwath, Martin Burger, Stuart Pettygrove, 

http://www.arb.ca.gov/research/rsc/10-18-13/item6dfr09-325.pdf

38Ibid., “Managing Dairy Manure in the Central Valley of California,” p. 41.
San Joaquin Valley Unified Air Pollution Control District September 18, 2014

A-32 Attachment A, Supplemental Documentation: Subpart 4 Requirements

2012 PM2.5 Plan and Rule 2201

solutions that focus on waste systems or technologies that minimize or eliminate 

emissions from existing waste management systems and processes, including wasteto-fuel systems, such as dairy digesters and other bio-fuel applications. The District has 

taken every regulatory action feasible to reduce emissions from this source and 

continues to seek additional methods to reduce emissions through innovative strategies 

such as the support of research and technology demonstrations with potential to reduce 

emissions further.

District Rule 4566, was adopted on August 18, 2011, to limit volatile organic compounds 

(VOC) emissions from composting facilities whose feedstock consists of greenwaste 

and/or foodwaste. District Rule 4566 applies to operations that stockpile and compost 

greenwaste and foodwaste. In addition to limiting VOC emissions, District Rule 4566

also limits ammonia (NH3) emissions from these operations. The analysis below 

focuses on how District Rule 4566 limits NH3 emissions in comparison to other rules 

and regulations.

II. How does District Rule 4566 compare with federal rules and regulations?

A. EPA-Control Technique Guidelines (CTG)

There is no EPA CTG guidance document for greenwaste or foodwaste

composting operations.

B. EPA - Alternative Control Technology (ACT)

There is no EPA ACT guidance document for greenwaste or foodwaste 

composting operations.

C. Standards of Performance for New Stationary Sources (NSPS)

There is no NSPS guidance document for greenwaste or foodwaste composting 

operations.

D. National Emission Standards for Hazardous Air Pollutants (NESHAPs) and 

Maximum Achievable Control Technologies (MACTs)

There is no NESHAP guidance document for greenwaste or foodwaste

composting operations.

III. How does District Rule 4566 compare to rules in other air districts?

District staff compared District Rule 4566 with the rules for greenwaste and foodwaste 

composting operations from other California air districts. The results of the analysis are 

discussed below. District staff only located one other air district rule that applied to 

similar sources: South Coast Air Quality Management District (SCAQMD) Rule 1133.3. 

No other air district rules that applied to greenwaste or similar sources were found. 
San Joaquin Valley Unified Air Pollution Control District September 18, 2014

A-33 Attachment A, Supplemental Documentation: Subpart 4 Requirements

2012 PM2.5 Plan and Rule 2201

A. South Coast Air Quality Management District (SCAQMD) Rule 1133.3 -

Emission Reductions from Greenwaste Composting Operations (Adopted 

July 8, 2011)

The purpose of SCAQMD Rule 1133.3 is to reduce emissions of volatile organic 

compounds (VOC) and ammonia (NH3) from greenwaste and foodwaste composting 

operations. The table below compares the significant similarities and differences 

between SJVAPCD Rule 4566 and SCAQMD Rule 1133.3. For purposes of this 

analysis, the ammonia control efficiencies achieved by the requirements of 

SJVAPCD Rule 4566 are assumed to be the same as the VOC control efficiencies 

since the same control measures will reduce both VOC and NH3 from these 

operations. It is worth noting that greenwaste/foodwaste composting produces about 

16% of the ammonia emissions on a per ton basis compared to co-composting.39 

 

39 SCAQMD Rule 1133.3, baseline NH3 emissions from greenwaste/foodwaste composting = 0.46 lbNH3/ton-throughput. SCAQMD Rule 1133.2, baseline NH3 emissions from co-composting = 2.93 lbNH3/ton-throughput.
San Joaquin Valley Unified Air Pollution Control District September 18, 2014

A-34 Attachment A, Supplemental Documentation: Subpart 4 Requirements

2012 PM2.5 Plan and Rule 2201

Rule Section SCAQMD Rule 

1133.3

SJVUAPCD Rule 

4566

Explanation of Differences

Applicability

New and existing 

greenwaste and 

foodwaste composting 

operations. 

New and existing organic 

material composting and 

stockpiling facilities. 

(Organic material is 

defined as green 

material, food material, or 

mixtures of the two, with 

<100 ton/yr biosolids or 

manure.)

SCAQMD Rule 1133.3 limits 

foodwaste stockpiling time (48 hr), 

whereas SJVAPCD Rule 4566 limits 

organic material stockpiling time (3 or 

10 days, depending on throughput).

Exemptions

Applicability/exemptions 

based on facility type, 

not throughput. 

Applicability/exemptions 

based on facility type, not 

throughput. 

The same types of facilities are 

exempt in both rules: facilities subject 

to a co-composting rule (SCAQMD 

Rule 1133.2 or SJVAPCD Rule 4565, 

nursery, household, recreational, and 

community composting facilities. 

SJVAPCD Rule 4566 also exempts 

agricultural facilities which are subject 

to SJVAPCD Rule 4204, 4550, or 

4570. 

Composting Control 

Requirements

 ≤5,000 ton/yr 

foodwaste or ≤20% 

manure (watering and 

finished compost cover 

or ≥20% control for 

NH3)

 >5,000 ton/yr 

foodwaste, (emission 

control device with 

≥80% control for NH3)

 <200,000 ton/yr 

organic material 

(watering system or 

≥19% control for NH3), 

 ≥200,000 and 

<750,000 ton/yr 

organic material 

(watering system and 

finished compost cover 

or ≥60% control for 

NH3)

 ≥750,000 ton/yr 

organic material 

(emission control 

device with ≥80% 

control for NH3)

The throughput/control levels in Rule 

4566 are based on cost-effectiveness 

and socio-economic studies 

conducted by the District as part its 

Final Staff Report Revised Proposed 

New Rule 4566 (Appendices C and 

D, August 18, 2011). Rule 4566 

requires the same management 

practices and control requirements as 

Rule 1133.3; however, the throughput 

levels at which the stricter control 

requirements in Rule 4566 become 

triggered are much higher than in 

Rule 1133.3. Thus, on paper, Rule 

1133.3 appears to be more stringent 

than Rule 4566. However, SCAQMD 

does not have any greenwaste 

composting facilities (that are not 

under an experimental research 

permit) subject to the 80% control 

requirements of Rule 1133.3.

As shown in the table above, based on discussions with SCAQMD permitting and rule 

development staff, SCAQMD does not have any greenwaste composting production 

facilities subject to the 80% ammonia reduction requirement of Rule 1133.3. SCAQMD 

has recently issued Authority to Construct permits for two experimental research

greenwaste composting facilities located in Fontana and Riverside operated by Burrtec. 

The permits authorize Burrtec to perform greenwaste composting for one year (with the 

possibility of an extension) in order to evaluate the feasibility of three different compost 

emissions control technologies and conduct emissions testing for each technology. If at 

the end of the permitted experimental research period, Burrtec wanted to convert one or 
San Joaquin Valley Unified Air Pollution Control District September 18, 2014

A-35 Attachment A, Supplemental Documentation: Subpart 4 Requirements

2012 PM2.5 Plan and Rule 2201

both facilities into a regular greenwaste composting production facility, they would need to 

obtain new ATC permits. The Burrtec facilities then are not representative of a 

commercial production greenwaste composting facility.

RACT is generally understood to apply to existing sources. Because SCAQMD has no 

existing production greenwaste composting facilities that are subject to the 80% ammonia 

control requirement of Rule 1133.3, and the new facilities are permitted under 

experimental research exemptions, then Rule 1133.3 cannot be used to establish RACT 

as 80% for that category/throughput level of greenwaste composting. Moreover, the 

types of controls that will meet the 80% requirement are considered equivalent to Best 

Available Control Technology (BACT) for composting sources,40 which is a higher level of 

control than RACT. Therefore, SCAQMD exceeds RACT requirements.

B. No rules that apply to biosolids, animal manure, and/or poultry litter 

operations were located for the air districts listed below

 Amador County Air Pollution Control District (ACAPCD)

 Bay Area Air Quality Management District (BAAQMD)

 Eastern Kern County Air Pollution Control District (EKAPCD)

 El Dorado County Air Quality Management District

 Imperial County Air Pollution Control District (ICAPCD)

 Mojave Desert Air Quality Management District (MDAQMD)

 North Coast Unified Air Quality Management District (NCAQMD)

 Placer County Air Pollution Control District (PCAPCD)

 Sacramento Metropolitan Air Quality Management District (SMAQMD)

 San Diego County Air Pollution Control District (SDCAPCD)

 Ventura County Air Pollution Control District (VCAPCD)

 Yolo-Solano Air Quality Management District (YSAQMD)

C. Idaho Administrative Procedure Act (IDAPA) 58.01.01 Sections 760-764: Rules 

for the Control of Ammonia from Dairy Farms

The purpose of IDAPA 58.01.01 Sections 760-764 is to set forth requirements for 

the control of ammonia through best management practices (BMPs) for certain size 

dairy farms licensed by the Idaho State Department of Agriculture to sell milk for 

human consumption.

This regulation only applies to large dairies and does not apply to other agricultural 

facilities or facilities in which the primary activity is the production of compost. 

Therefore, it was determined that this regulation is not relevant to the current 

analysis since it does not specifically limit emissions from composting facilities.

 

40 SJVAPCD BACT Clearinghouse Guideline 6.4.9, Co-Composting Operation.
San Joaquin Valley Unified Air Pollution Control District September 18, 2014

A-36 Attachment A, Supplemental Documentation: Subpart 4 Requirements

2012 PM2.5 Plan and Rule 2201

Conclusion

After careful evaluation of federal rules and regulations as well as prohibitory rules in 

other California areas, District staff concludes that District Rule 4566 satisfies RACT for 

ammonia emissions from greenwaste and foodwaste composting operations.

A.4 Biosolids, Animal Manure, and Poultry Litter Operations (District Rule 4565)

I. District Rule Description:

District Rule 4565, was adopted on March 15, 2007, to limit volatile organic compounds 

(VOC) emissions from facilities whose throughput consists entirely or in part of 

biosolids, animal manure, or poultry litter. District Rule 4565 applies to operations that 

landfill, land apply, compost, or co-compost these materials. In addition to limiting VOC 

emissions, District Rule 4565 also limits ammonia (NH3) emissions from these 

operations. The analysis below focuses on how District Rule 4565 limits NH3 emissions 

in comparison to other rules and regulations.

II. How does District Rule 4565 compare with federal rules and regulations?

A. EPA-Control Technique Guidelines (CTG)

There is no EPA CTG guidance document for biosolids, animal manure, and/or 

poultry litter operations.

B. EPA - Alternative Control Technology (ACT)

There is no EPA ACT guidance document for biosolids, animal manure, and/or

poultry litter operations.

C. Standards of Performance for New Stationary Sources (NSPS)

There is no NSPS guidance document for biosolids, animal manure, and/or

poultry litter operations.

D. National Emission Standards for Hazardous Air Pollutants (NESHAPs) and 

Maximum Achievable Control Technologies (MACTs)

There is no NESHAP guidance document for biosolids, animal manure, and/or

poultry litter operations.

III. How does District Rule 4565 compare to rules in other air districts?

District staff compared District Rule 4565 with the rules for biosolids, animal manure, 

and poultry litter operations from other California air districts. The results of the analysis 

are discussed below. District staff only located one other air district rule that applied to 
San Joaquin Valley Unified Air Pollution Control District September 18, 2014

A-37 Attachment A, Supplemental Documentation: Subpart 4 Requirements

2012 PM2.5 Plan and Rule 2201

similar sources, South Coast Air Quality Management District (SCAQMD) Rule 1133.2. 

No other air district rules that applied to similar sources were found. 

A. South Coast Air Quality Management District (SCAQMD) Rule 1133.2 -

Emission Reductions from Co-Composting Operations (Adopted January 10, 

2003)

SCAQMD adopted SCAQMD Rule 1133.2. This rule applies to new and existing 

co-composting operations in the SCAQMD. 

Staff notes that there are some differences between District Rule 4565 and SCAQMD 

Rule 1133.2. This does not mean that one rule is more stringent than the other; 

rather the differences are due to the following factors:

1. Technology has changed significantly since SCAQMD Rule 1133.2 was 

adopted on January 10, 2003;

2. Additional research projects regarding mitigation measures have been 

completed since SCAQMD Rule 1133.2 was adopted; and 

3. The socioeconomic climate of the SCAQMD is significantly different from that 

of the San Joaquin Valley Unified Air Pollution Control District.

The table below summarizes the significant differences between SCAQMD Rule 

1133.2 and SJVAPCD Rule 4565. Below are the important differences between the 

two rules. For purposes of this analysis, the NH3 control efficiency for the 

requirements of SJVAPCD Rule 4565 are assumed to be the same as the VOC 

control efficiency for these requirements since the same measures will generally 

reduce both VOC and NH3 from these operations.
San Joaquin Valley Unified Air Pollution Control District September 18, 2014

A-38 Attachment A, Supplemental Documentation: Subpart 4 Requirements

2012 PM2.5 Plan and Rule 2201

Category SCAQMD 

Rule 1133.2

SJVUAPCD Rule 

4565

Reason

Facilities Other Than 

Co-Composting 

(Landfilling, Land 

Applying)

Rule does not 

apply to these 

operations

Management practice

requirements

Knowledge of control options has 

increased since Rule 1133.2 adoption 

and staff believes that cost-effective 

methods of controlling VOC and NH3

emissions from these facilities exist.

Co-Composting 

Threshold for 

Applicability

Facilities with at 

least 1,000 tpy 

throughput

Facilities that handle 100 

tpy or more of biosolids, 

animal manure, or 

poultry litter

Staff believes that there are reasonable 

options that are not exceedingly costly 

for facilities with throughputs of 100 

tpy that would not impose an undue 

burden on operators.

Composting Control 

Requirements

In-vessel 

composting with 

70% control 

efficiency for 

VOC and NH3 

for existing 

facilities and 

80% control 

efficiency for 

VOC and NH3 

for new facilities

Control efficiency of 10% 

- 80% for VOC (and 

NH3) depending on type 

of operation and facility 

throughput

Management practices (mitigation 

measures) are effective, reasonable, 

and have been achieved in practice for 

smaller facilities.

In-vessel composting is not costeffective for smaller or medium facilities 

and there are no known, unsubsidized 

facilities in the SCAQMD that would 

comply with such rule requirements.

It should also be noted that in practice, the facilities that are actually subject to 

SCAQMD Rule 1133.2 will have much larger throughputs than 1,000 ton per year 

throughput threshold given in the rule. SCAQMD Rule 1133.2 includes the 

following exemptions for existing co-composting operations with a design capacity 

of less than 35,000 tons of throughput per year containing no more than 20 percent 

biosolids by volume and new and existing municipal facilities using aeration and 

processing less than 5,000 tons of biosolids or manure per year. In addition many 

operations in the SCAQMD have found it to be economical to transport these 

materials to other jurisdictions for processing. An example of this is the Synagro 

South Kern Compost Manufacturing Facility, which is a newer facility located in the 

San Joaquin Valley and processes biosolids transported from SCAQMD. 

Because some mitigation measures are only cost-effective for larger facilities, 

SJVAPCD staff developed the concept of Class One and Class Two mitigation 

measures. Class One mitigation measures are cost-effective options for all 

facilities, regardless of size. These measures are management practices found to 

be best practices for all composting operations. 

Class Two mitigation measures are the technology options and achieve reductions 

greater than Class One mitigation measures; however, they were determined to not 

be cost effective for facilities with throughputs of less than 100,000 wet tons per 

year.

SJVAPCD Rule 4565 requires reductions from two additional categories (landfilling 

and land applying) when compared to SCAQMD Rule 1133.2. For the third 
San Joaquin Valley Unified Air Pollution Control District September 18, 2014

A-39 Attachment A, Supplemental Documentation: Subpart 4 Requirements

2012 PM2.5 Plan and Rule 2201

category, composting, SJVAPCD staff determined it is not cost effective to require 

in-vessel (enclosed) composting.

B. No rules that apply to biosolids, animal manure, and/or poultry litter 

operations were located for the air districts listed below

 Amador County Air Pollution Control District (ACAPCD)

 Bay Area Air Quality Management District (BAAQMD)

 Eastern Kern County Air Pollution Control District (EKAPCD)

 El Dorado County Air Quality Management District

 Imperial County Air Pollution Control District (ICAPCD)

 Mojave Desert Air Quality Management District (MDAQMD)

 North Coast Unified Air Quality Management District (NCAQMD)

 Placer County Air Pollution Control District (PCAPCD)

 Sacramento Metropolitan Air Quality Management District (SMAQMD)

 San Diego County Air Pollution Control District (SDCAPCD)

 Ventura County Air Pollution Control District (VCAPCD)

 Yolo-Solano Air Quality Management District (YSAQMD)

C. Idaho Administrative Procedure Act (IDAPA) 58.01.01 Sections 760-764: Rules 

for the Control of Ammonia from Dairy Farms

The purpose of IDAPA 58.01.01 Sections 760-764 is to set forth requirements for 

the control of ammonia through best management practices (BMPs) for certain size 

dairy farms licensed by the Idaho State Department of Agriculture to sell milk for 

human consumption.

This regulation only applies to large dairies and does not apply to other agricultural 

facilities or facilities in which the primary activity is the production of compost. 

Therefore, it was determined that this regulation is not relevant to the current 

analysis since it does not specifically limit emissions from composting facilities.

Conclusion

After careful evaluation of federal rules and regulations as well as prohibitory rules in 

other California areas, District staff concludes that District Rule 4565 satisfies RACT for 

biosolids, animal manure, and poultry litter operations.

A.5 Major Sources of Ammonia

The facilities listed below were identified as potential major sources of NH3 in the San 

Joaquin Valley Air basin. In all cases the NH3 emissions from the facilities were entirely 

or primarily the direct result of the use of catalytic emission controls to reduce NOx 

emissions to acceptable levels as determined by regulatory agencies including, the US 

EPA, the California Air Resources Board, the San Joaquin Valley APCD, and, in one 
San Joaquin Valley Unified Air Pollution Control District September 18, 2014

A-40 Attachment A, Supplemental Documentation: Subpart 4 Requirements

2012 PM2.5 Plan and Rule 2201

case the California Energy Commission (CEC). Because the San Joaquin Valley Air 

basin is primarily a rural NOx-limited area, NOx reductions are the most critical element 

of San Joaquin Valley plans to reach attainment with the federal ambient air quality 

standards for both PM2.5 and ozone. Therefore, controls that reduce NH3 

whileincreasing NOx would increase the formation of PM2.5 and ozone in the San 

Joaquin Valley and would be detrimental to the goals of reaching attainment with the 

federal ambient air quality standards.

Facility Name: J.R. Simplot Company; District Facility #C-705 

This facility produces fertilizers. The NH3 emissions from this facility are associated 

with the Nitric acid production plant at the facility. Although ammonia is used in the 

production of nitric acid, the vast majority of the ammonia introduced is consumed in the 

production of the nitric acid or recovered. The ammonia emissions from the nitric acid 

are the result of the use of a non-selective catalytic reduction (NSCR) system to reduce 

NOx emissions from the nitric acid plant. The tail gas from nitric acid plants contains 

large amounts of NOx and this plant uses NSCR to reduce NOx to comply with 40 CFR 

60 Subpart G - Standards of Performance for Nitric Acid Plants and Federallyenforceable New and Modified Source Review (NSR) limits. The NSR permit for this 

facility includes conditions minimizing the allowable amount of NH3 slip with associated 

emissions testing. Because the NH3 emissions are the direct result of the use of 

NSCR, which is required to comply with Federal NSPS and NSR requirements, and 

reducing the amount of NH3 would increase NOx emissions, this facility is considered to 

satisfy RACT for NH3.

Facility Name: Covanta Delano Inc.; District Facility #S-75 

This facility is biomass power plant. The NH3 emissions from this facility are the result 

of the use of NH3 injection for Selective Non-Catalytic Reduction (SNCR) to control 

NOx from two biomass-fired boilers at the facility. Use of the SNCR to reduce NOx is 

required by the EPA-issued Prevention of Significant Deterioration (PSD) Permit PSD 

ATC SJ 90-01 and Federally-enforceable NSR conditions and also required to comply 

with 40 CFR 60 Subpart Db—Standards of Performance for Industrial-CommercialInstitutional Steam Generating Units. The NSR permits state, “Ammonia shall be

injected into boiler at a rate, in pounds per ton of biomass fuel introduced into boiler, 

which results in compliance with the NOx emission limitation.” and Permit PSD ATC SJ 

90-01 states “... A SNCR system utilizing ammonia injection shall be incorporated within 

the boilers. Ammonia shall be injected continuously during all periods of operation at a 

rate which results in compliance with the NOx emission limits. ...” Because a perfect 

reaction cannot be achieved, some excess NH3 must be injected in the boiler stacks to 

reduce NOx to acceptable levels and this excess unreacted NH3 escapes the stack as 

slip. The facility incurs a cost for all of the NH3 injected into the boiler stacks, so there 

is an incentive to minimize NH3 slip to reduce costs associated with compliance with the 

NOx limits. In addition, the NSR permits for the biomass-fired boilers include conditions 

limiting the allowable amount of NH3 slip.

The NH3 emissions from the biomass boilers are the direct result of the use of SNCR, 

which is required by NSR conditions and the EPA-issued PSD Permit PSD ATC SJ 90-
San Joaquin Valley Unified Air Pollution Control District September 18, 2014

A-41 Attachment A, Supplemental Documentation: Subpart 4 Requirements

2012 PM2.5 Plan and Rule 2201

01 and required to comply with the requirements of Federal NSPS. The NSR permits 

for the biomass-fired boilers include conditions limiting the allowable amount of NH3 slip 

with associated emissions testing, and further reducing the amount of NH3 could 

potentially increase NOx emissions; therefore, this facility is considered to satisfy RACT 

for NH3. 

Facility Name: Northern California Power; District Facility #N-2697 

This facility is a natural gas power plant. The NH3 emissions from this facility are the 

result of the use of NH3 injection for Selective Catalytic Reduction (SCR) to control NOx 

from two natural gas-fired turbines at the facility. Use of the SCR to reduce NOx is 

required by Federally-enforceable NSR conditions and also required to comply with the 

Federally-enforceable requirements of District Rule 4703 – Stationary Gas Turbines, 

which is included in the SIP. Because a perfect reaction cannot be achieved, some 

excess NH3 must be injected to reduce NOx to acceptable levels. The excess 

unreacted NH3 escapes the stack as slip. The facility incurs a cost for all of the NH3 

injected into the stacks, so there is an incentive to minimize NH3 slip to reduce costs 

associated with the compliance with the NOx limits. In addition, the NSR permits for the 

natural gas-fired turbines include conditions limiting the allowable amount of NH3 slip.

The NH3 emissions from the natural gas-fired turbines are the direct result of the use 

SCR, which is required by NSR conditions and required to comply with the Federallyenforceable requirements of District Rule 4703. The NSR permits for the natural gasfired turbines include conditions limiting the allowable amount of NH3 slip and 

associated emissions testing, and further reducing the amount of NH3 could potentially 

increase NOx emissions; therefore, this facility is considered to satisfy RACT for NH3.