1 Final Staff Report with Appendices 

For Amendments to Rule 4905

SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

FINAL STAFF REPORT 

Amendments to Rule 4905 

(Natural Gas-fired, Fan-Type Central Furnaces) 

January 22, 2015 

Prepared by: Jesse Madsen, Air Quality Specialist 

Reviewed by: Sharla Yang, Air Quality Specialist 

 Brian Clerico, Air Quality Engineer II 

Patrick Houlihan, Senior Air Quality Specialist 

Anna Myers, Senior Air Quality Specialist

Errol Villegas, Strategies and Incentives Manager 

Sheraz Gill, Director of Strategies and Incentives

I. SUMMARY 

Through extensive efforts during the development of the 2008 PM2.5 Plan, the San 

Joaquin Valley Air Pollution Control District (District) identified the opportunity to reduce 

the oxides of nitrogen (NOx) emissions from sources subject to Rule 4905. This would be 

accomplished by lowering the NOx emission limit for natural-gas-fired, fan-type residential 

central furnaces (residential units) with a rated heating capacity of less than 175,000 

British thermal units per hour (Btu/hr), and for combination heating and cooling units with 

a rated cooling capacity of less than 65,000 Btu/hr.

1

 The District initially committed to 

amend Rule 4905 (Natural Gas-fired, Fan-type Residential Central Furnaces) in 2010; 

however, because advanced low-NOx technology was still in the early stages of 

development for residential furnaces, the District revised its commitment in the 2008 

PM2.5 Plan to amend Rule 4905 in 2014.2

 The District’s 2012 PM2.5 Plan3 and 2013 Plan 

for the Revoked 1-Hour Ozone Standard4

include this commitment and an additional 

commitment to explore the feasibility and cost effectiveness of adding a NOx emission limit 

for units installed in commercial buildings (commercial units). 

 

The purpose of the rule amendment is to fulfill the commitments in the 2008 PM2.5 Plan, 

2012 PM2.5 Plan, and 2013 Plan for the Revoked 1-Hour Ozone Standard to further 

 

1

 SJVAPCD. (2008, April 30). 2008 PM2.5 Plan. Retrieved 9/29/14 from 

http://www.valleyair.org/Air_Quality_Plans/AQ_Final_Adopted_PM25_2008.htm. 

2

 SJVAPCD. (2010, June 17). Proposed Amendment to the 2008 PM2.5 Plan to Extend the Rule Amendment 

Schedule for Rule 4905 (Natural Gas-Fired, Fan-Type Residential Central Furnaces. Retrieved 9/29/14 from 

http://valleyair.org/Board_meetings/GB/agenda_minutes/Agenda/2010/June/Agenda_Item_9_June_17_2010.pdf. 

3

 SJVAPCD. (2012, December 20). 2012 PM2.5 Plan. Retrieved 5/22/13 from 

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

4

 SJVAPCD. (2013, September 19). 2013 Plan for the Revoked 1-Hour Ozone Standard. Retrieved 9/29/14 from 

http://www.valleyair.org/Air_Quality_Plans/OzoneOneHourPlan2013/AdoptedPlan.pdf. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Final Staff Report: Rule 4905 January 22, 2015 

2 Final Staff Report with Appendices 

For Amendments to Rule 4905

reduce NOx emissions from residential units and explore the possibility of extending rule 

applicability to include NOx emission limits for commercial units. The amendments are 

analogous to the requirements of South Coast Air Quality Management District 

(SCAQMD) Rule 1111 (NOx Emissions from Natural Gas-fired, Fan type Central 

Furnaces) and provide for regulatory consistency in California. Amendments include the 

following: 

• Lower the NOx emission limit for residential units to 14 nanograms of NOx per joule 

of heat output (ng/J) , 

• Expand the applicability to include commercial units with a NOx emission limit of 14 

ng/J,

• Expand the applicability to include units installed in manufactured homes with an 

initial NOx emission limit of 40 ng/J which will then be lowered to 14 ng/J in 2018, 

and 

• Allow the sale of non-compliant units during the initial implementation period (36-

months) in exchange for the payment of an emissions fee for each non-compliant 

unit sold 

SCAQMD amended Rule 1111 in November 2009 to lower the NOx emission limit for 

applicable units from 40 ng/J to 14 ng/J,5

 and amended it again in September 2014 to 

extend the first compliance deadline and add an emissions fee option.6 SCAQMD Rule 

1111 already applies to both residential and commercial furnaces, and units installed in 

manufactured homes have been required to comply with a 40 ng/J limit since October 

2012 and will be required to comply with a 14 ng/J limit starting October 2018. Because 

no compliant units for the new lower NOx limit were commercially available at the time of 

the 2009 amendment, SCAQMD and the District co-funded a technology assessment to 

evaluate the performance of ultra-low NOx furnace technologies.7 The technology 

assessment resulted in the successful demonstration of several low-NOx furnace designs, 

which are expected to be commercially available by the SCAQMD Rule 1111 compliance 

dates. 

The District expects technology required for compliance with amendments to be 

commercially available by the SCAQMD Rule 1111 compliance dates and is therefore 

proposing to amend Rule 4905 as described above. For those manufacturers that are not 

able to respond to increased demand for new units by the compliance dates, the 

emissions fee option will allow them the option to continue selling units in the San Joaquin 

Valley (Valley). Rule amendments contribute to the Valley’s progress towards attainment 

of federal air quality standards for PM2.5 and ozone by reducing NOx, which is a 

 

5

 SCAQMD. (2009, November 6). Final Staff Report with Socioeconomic Impact Assessment. Retrieved 9/16/14 from 

http://www3.aqmd.gov/hb/2009/November/091130a.htm. 

6

 SCAQMD. (2014, September 5). Governing Board Agenda Item, September 5, 2014: Amend Rule 1111 – 

Reduction of NOx Emissions from Natural-gas-fired, Fan-type Central Furnaces. Retrieved 9/9/14 from 

http://www.aqmd.gov/docs/default-source/Agendas/Governing-Board/2014/2014-sep5-032.pdf?sfvrsn=2. 

7

 SCAQMD. (2014, September 5). Governing Board Agenda Item, September 5, 2014: Amend Rule 1111 – 

Reduction of NOx Emissions from Natural-gas-fired, Fan-type Central Furnaces. Retrieved 9/9/14 from 

http://www.aqmd.gov/docs/default-source/Agendas/Governing-Board/2014/2014-sep5-032.pdf?sfvrsn=2. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Final Staff Report: Rule 4905 January 22, 2015 

3 Final Staff Report with Appendices 

For Amendments to Rule 4905

precursor for both PM2.5 and ozone. Amendments to Rule 4905 will achieve an 

estimated 2.10 tons per day (tpd) of NOx emission reductions and ensure that Rule 4905 

aligns with similar rules in other California air districts. 

II. PROJECT BACKGROUND 

A. Source Category 

Rule 4905 is a point-of-sale rule that applies to any person who supplies, sells, offers for 

sale, installs, or solicits the installation of natural-gas-fired, fan-type residential central 

furnaces with a rated heat input capacity of less than 175,000 Btu/hr and a rated cooling 

capacity of less than 65,000 Btu/hr for combination heating and cooling units. Affected 

parties include furnace manufacturers, residential heating wholesalers, supply stores, 

contractors and end-users. The point-of-sale approach has allowed the District to 

achieve NOx reductions without placing an undue financial burden on the residents, 

operators and businesses that sell these units in the Valley. 

The above units are used in approximately 71% of Valley residences8

 and are not 

labeled for retail as “residential” or “commercial” furnaces. Units used in commercial 

buildings, while currently not subject to the requirements of Rule 4905, are essentially 

the same as residential units with the exception of possible differences in usage 

patterns and indoor/outdoor location. An estimated 1,252,190 residential and 

commercial units will be operating in the Valley in 2017 (see Appendix C). 

Replacement will occur gradually as these units reach the end of the 20-year useful life. 

The most common residential and commercial heat sources are boilers and furnaces; 

other heating options include heat pumps, active solar heating, electric heating, wood or 

pellet stoves, portable and direct vent wall heaters, and fireplaces.9 Heat distribution 

systems are either central heating, meaning heat is generated in a central location and 

distributed throughout the building, or point-of-use or space heating, meaning 

supplemental heat is provided to a specific room. Types of central heating systems 

include forced air, steam radiant, radiant, hot water baseboards, and electric 

baseboards. Types of space heaters include wood or pellet stoves, portable and direct 

vent wall heaters, and fireplaces. Fuel types include natural gas, propane, heating oil, 

electricity, and solid fuels such as wood or pellets. 

All heating systems have three basic components: a heat source, a heat distribution 

system, and a control system. The control system is usually a programmable 

thermostat. The heat source, which generally determines the type of distribution system 

used, is selected based on many factors. The most important factor is geographical 

 

8

 KEMA, Inc. (Prepared for California Energy Commission). (2010, October). 2009 California Residential Appliance 

Saturation Study. Retrieved 9/17/13 from http://www.energy.ca.gov/2010publications/CEC-200-2010-004/CEC-200-

2010-004-ES.PDF. 

9

 Department of Energy. (2013, December 16). Energy Saver 101: Everything You Need to Know About Home 

Heating. Retrieved 12/17/13 from http://energy.gov/articles/energy-saver-101-infographic-home-heating. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Final Staff Report: Rule 4905 January 22, 2015 

4 Final Staff Report with Appendices 

For Amendments to Rule 4905

location, which determines the climate and types of available fuel. Most commercial 

and residential buildings in the Valley have access to natural gas, which is typically the 

cheapest and most convenient fuel source in areas where it is available. 

Rule 4905 applies to furnaces fueled by natural gas that use forced air distribution, the 

most common type of heating system for residential and commercial buildings. Central 

furnaces are controlled by a thermostat, which sends signals to turn the device on or off 

when the building temperature does not match a chosen set point. A valve then opens 

to send natural gas to the burners, which combust the gas directly into the heat 

exchangers. A blower pulls air from outside the building through a filter, across the heat 

exchanger, and through a series of ducts and vents to different areas of the building. 

Exhaust from the combustion exits the building through a separate duct. Condensing 

units use an additional heat exchanger to extract the latent heat in the flue (exhaust) 

gas by cooling the combustion gasses to near ambient temperature and thereby 

increase the heating efficiency by up to 10%. The water vapor in the flue gas is 

condensed, collected, and drained. 

Units installed in manufactured homes utilize the same types of materials and operating 

principles as commercial and residential units; however, significant differences exist. 

Furnaces installed in manufactured homes use sealed combustion, meaning all of the 

combustion air is taken from outside the building. These units also pre-heat the air, 

typically to 50-60°F, using a concentric vent where the combustion air is drawn in 

through the outer ring, while exhaust gases are vented through the inside core of the 

vent pipe. The air is pre-heated because the cold outside air does not mix well with the 

fuel, while pre-heated air blends well and allows for quieter ignition and combustion. 

Furnaces installed in manufactured homes also have to comply with strict space 

restrictions.10 Amendments allow until October 1, 2018 to comply for these units. 

B. Current Rule 

The purpose of Rule 4905 is to limit NOx emissions from natural gas-fired, fan-type 

residential central furnaces with rated heat inputs less than 175,000 Btu/hr and for 

combination heating and cooling units rated at a cooling capacity less than 65,000 

Btu/hr. The rule currently requires that no person supply, sell, offer for sale, install, or 

solicit the installation of any unit within the Valley that exceeds a NOx emission limit of 

0.093 lb/MMBtu or 55 ppmv; this NOx emission limit is equivalent to 40 ng/J. The rule is 

not applicable to units installed in manufactured homes, nonfan-type units and units 

using fuel other than natural gas. 

Rule 4905 requires that manufacturers of units subject to the rule certify their units 

through either the District’s certification program, the SCAQMD certification process for 

 

10 U.S. Department of Energy. (2014, July 7). Energy Conservation Program for Consumer Products: Energy 

Conservation Standards for Residential Furnace Fans. Retrieved 9/23/14 from 

https://www.federalregister.gov/articles/2014/07/03/2014-15387/energy-conservation-program-for-consumerproducts-energy-conservation-standards-for-residential. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Final Staff Report: Rule 4905 January 22, 2015 

5 Final Staff Report with Appendices 

For Amendments to Rule 4905

SCAQMD Rule 1111, or another emission certification program approved by the United 

States Environmental Protection Agency (EPA) and District’s Air Pollution Control 

Officer. Manufacturers are also required to display the model number of the unit on the 

shipping container and rating plate. If requested by the APCO, each manufacturer must 

submit a statement confirming the unit is in compliance, including a source test report 

verifying compliance with the emission limit. 

The District’s Governing Board adopted Rule 4905 on October 20, 2005 to establish the 

NOx limits mentioned above. EPA finalized approval for Rule 4905 on May 30, 2007. 

 

C. South Coast AQMD Rule 1111 

SCAQMD adopted Rule 1111 (Reduction of NOx Emissions from Natural-Gas-Fired, 

Fan-type Central Furnaces) in December 1978 to limit NOx emissions from the same 

units as Rule 4905. The rule was amended in July 1983, November 2009, and 

September 2014. 

The July 1983 amendment to SCAQMD Rule 1111 expanded applicability to include 

commercial units. November 2009 amendments lowered the NOx limit for residential 

and commercial units from 40 ng/J to 14 ng/J and added a requirement for units 

installed in manufactured homes to comply with a 40 ng/J limit starting in October 2012 

and a 14 ng/J limit starting in October 2018. Tiered compliance deadlines were set for 

condensing, non-condensing, and weatherized units on October 1 of 2014, 2015, and 

2016, respectively. The 2009 amendments also established an incentive program for 

early compliance and committed to conducting a technology assessment to develop and 

test ultra-low-NOx burner technologies.11

The September 2014 amendments extended the October 1, 2014 compliance deadline 

for condensing units to April 1, 2015 to provide manufacturers additional time for testing 

new furnace designs and submitting and receiving approval of compliance plans for 

selling non-compliant condensing units. An emissions fee option was added to allow 

manufacturers to pay to sell non-compliant units for up to 36 months after the applicable 

compliance date. The emissions fees are set at $150 for non-condensing units and 

$200 for condensing units. The fees were set based on upper-limit estimates of the 

expected cost increase for consumers to purchase new compliant units. Manufacturers 

of units complying with the 14 ng/J emission limit, 90 days prior to the applicable 

compliance date, may receive $75 in incentive monies for each non-condensing unit 

and $90 for each condensing unit.12

 

11 SCAQMD. (2009, November 6). Final Staff Report with Socioeconomic Impact Assessment. Retrieved 9/16/14 

from http://www3.aqmd.gov/hb/2009/November/091130a.htm. 

12 SCAQMD. (2014, September 5). Governing Board Agenda Item, September 5, 2014: Amend Rule 1111 – 

Reduction of NOx Emissions from Natural-gas-fired, Fan-type Central Furnaces. Retrieved 9/9/14 from 

http://www.aqmd.gov/docs/default-source/Agendas/Governing-Board/2014/2014-sep5-032.pdf?sfvrsn=2. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Final Staff Report: Rule 4905 January 22, 2015 

6 Final Staff Report with Appendices 

For Amendments to Rule 4905

D. Control Technology 

At the time of the November 2009 amendment to SCAQMD Rule 1111, no compliant 

units were available to meet the new 14 ng/J emission limit. The District partnered with 

SCAQMD to fund a technology assessment, with additional funding provided by 

Southern California Gas Company, to develop and test low-NOx furnace technologies. 

The manufacturer-specific details of the technologies developed during this assessment 

remain proprietary and confidential; however, the assessment was completed in the first 

quarter of 2014 and resulted in the successful development and testing of several 

prototypes that achieved the 14 ng/J NOx emission limit from SCAQMD Rule 1111.13

Four participants were selected to develop and test prototypes including two furnace 

manufacturers, a burner manufacturer, and a research institute experienced with 

combustion technologies. Successful prototypes included condensing and noncondensing furnaces with single and variable firing rates and a variety of heat input 

capacities that encompassed the sizes of most units found in residential and small 

commercial buildings. These prototypes demonstrated that the 14 ng/J NOx emission 

limit is achievable in all unit types subject to Rule 4905, although development of units 

installed in manufactured homes will likely take significantly longer. The prototypes 

implemented enhanced pre-mixing and modified burners and passed safety and 

reliability testing. 

At the time of completion for the technology assessment, manufacturers still faced 

several obstacles to commercialization including design, materials, controls, and 

manufacturing. Conversations with technology assessment participants indicated that 

most manufacturers will have new compliant furnaces commercially available by the 

SCAQMD Rule 1111 compliance deadlines, and more than one manufacturer claimed 

to already have compliant units ready for commercialization. However; a few of the 

manufacturers, and the Air Conditioning, Heating, and Refrigeration Institute (AHRI) 

raised concerns regarding the compliance dates and requested an option that allows 

the sale of non-compliant units during the initial implementation period in exchange for 

emissions fees. 

One manufacturer indicated that their primary focus has been on meeting expected 

demand in Southern California and additional time is needed to meet expected demand 

in the San Joaquin Valley. Another manufacturer has developed compliant units, but 

expressed the need for additional time to demonstrate the reliability and durability 

necessary to be able to go to market. However, information obtained through the multiagency technology assessment project indicated that due to low anticipated demand, 

high cost to produce, new and costly tooling, and other products with higher potential 

 

13 SCAQMD. (2014, September 5). Governing Board Agenda Item, September 5, 2014: Amend Rule 1111 – 

Reduction of NOx Emissions from Natural-gas-fired, Fan-type Central Furnaces. Retrieved 9/9/14 from 

http://www.aqmd.gov/docs/default-source/Agendas/Governing-Board/2014/2014-sep5-032.pdf?sfvrsn=2. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Final Staff Report: Rule 4905 January 22, 2015 

7 Final Staff Report with Appendices 

For Amendments to Rule 4905

return on investment currently using development resources, the manufacturer is not 

actively pursuing the development and manufacturing of complying units. 

III. AMENDMENTS TO RULE 4905 

A. Overview 

The District is implementing the following amendments to Rule 4905: 

• Lower the NOx emission limit for residential units to 14 ng/J14

• Expand the applicability of Rule 4905 to include: 

o Commercial units with a NOx emission limit of 14 ng/J 

o Units installed in manufactured homes with a NOx emission limit of 40 

ng/J, and lower that NOx emission limit to 14 ng/J in 2018 

• Allow the sale of non-compliant units during the initial implementation period (36-

months) in exchange for the payment of an emissions fee for each non-compliant 

unit sold 

• Add labeling requirements to new units shipped to or sold in the Valley 

• Remove redundant and expired language, including Section 7.0 (Compliance 

Schedule) 

B. Amendments to Rule 4905 

The following discussion details the amendments to Rule 4905. See Rule 4905 for 

exact language. 

Section 1.0—Purpose 

Amendments removed the word “residential” to expand the purpose of Rule 4905 to 

include commercial units and units installed in manufactured homes. 

Section 2.0—Applicability 

The word “residential” was removed to expand rule applicability to include commercial 

units of the same type and in the same size range and units installed in manufactured 

homes. Commercial units in this size range are essentially the same as residential 

units. According to industry representatives, natural gas-fired, fan-type central furnaces 

are not labeled as “residential” or “commercial” when sold. The word “District” was 

replaced with “San Joaquin Valley Air Basin” to improve clarity. 

 

14 The previous version of Rule 4905 used pounds of NOx per million British thermal units of heat output (lb/MMBtu). 

Amended Rule 4905 uses nanograms NOx per joule of heat output (ng/J) to allow for regulatory consistency in 

California. The two units of measurement are interchangeable using equivalency factors. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Final Staff Report: Rule 4905 January 22, 2015 

8 Final Staff Report with Appendices 

For Amendments to Rule 4905

Section 3.0—Definitions 

To improve clarity, the term and definition for “Fan-type Residential Central Furnace” 

(3.4) was amended to delete “residential” to reflect expansion of rule applicability. The 

same definition for “Condensing Unit” as used in SCAQMD Rule 1111, for use with the 

tiered compliance deadlines was added to the rule. Redundant language was removed 

from definitions 3.6 (Heat Output (Central Furnace)) and 3.7 (Manufactured Home). 

The term “Annual Fuel Utilization Efficiency” is already defined in 3.2; hence, the 

definition does not need to be repeated. Similarly, the United States Code and 

California Health and Safety Code references are included in the definition for 

Manufactured Home, making the language from those references redundant and 

unnecessary. Subsection numbers were changed to reflect the amendments. 

Definition 3.12 was added to the rule to define “responsible official” as “for the purposes 

of this rule: for a corporation, a president or vice-president of the corporation in charge 

of a principal business function or a duly authorized person who performs similar policymaking functions; for a partnership or sole proprietorship, a general partner or 

proprietor, respectively.” Definition 3.13 was added to the rule to define “weatherized 

unit” as “for the purposes of this rule, designed for installation outside of a building, 

equipped with a protective jacket and integral venting, and labeled for outdoor 

installation,” consistent with SCAQMD Rule 1111. 

Section 4.0—Exemptions 

All exemptions were removed from the rule and the section has been reserved for 

potential future exemptions. 

Section 5.0—Requirements 

More Stringent NOx Emission Limits 

Amendments lowered the NOx emission limit to 14 ng/J for residential units with a rated 

heat input of less than 175,000 Btu/hr, and for combination heating and cooling units a 

rated cooling capacity of less than 65,000 Btu/hr. Amendments also require new 

commercial units to meet the 14 ng/J NOx emission limit and require new units installed 

in manufactured homes to meet a NOx emission limit of 40 ng/J. The amended NOx 

emission limits in Table 1 take effect pursuant to the compliance dates in the same 

table. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Final Staff Report: Rule 4905 January 22, 2015 

9 Final Staff Report with Appendices 

For Amendments to Rule 4905

Table 1 NOx Emission Limits (Effective on and after February 1, 2015) 

Unit Type NOx Emission Limit 

(ng/J heat output) 

Compliance 

Date 

Units installed in manufactured homes 40 February 1, 

2015 

All non-weatherized condensing units except 

those installed in manufactured homes 14 April 1, 2015 

All non-weatherized, non-condensing units 

except those installed in manufactured homes 14 October 1, 2015 

Weatherized units 14 October 1, 2016 

Units installed in manufactured homes 14 October 1, 2018 

Compliance Deadlines 

Amendments provide retailers the opportunity to sell through existing stock consisting of 

units manufactured prior to the applicable compliance dates in Table 1 until the sellthrough period end dates in Table 2, provided the units are compliant with labeling 

requirements and the standards in effect on the date of manufacture. 

Table 2 Sell-through Period End-Dates for Units Manufactured Prior to the Applicable 

Compliance Dates in Table 1 

Unit Type Sell-through Period End-date 

All non-weatherized condensing units except 

those installed in manufactured homes January 26, 2016 

All non-weatherized, non-condensing units 

except those installed in manufactured homes July 27, 2016 

Weatherized units July 27, 2017 

Units installed in manufactured homes (for 

certified 40 ng/J units) July 27, 2019 

SCAQMD included the same tiered compliance deadlines based on unit type to 

accommodate difficulties associated with commercializing different unit types. This 

accommodation was granted because the SCAQMD NOx emission limits were 

scheduled to take effect October 2014 for condensing units, but some manufacturers 

needed additional time to commercialize the newly developed compliant units. Based 

on the results of the low-NOx furnace technology assessment and discussions with 

manufacturers and industry representatives, the technology for compliant units will be 

available by the SCAQMD Rule 1111 compliance dates, and some units are even 

expected to be available at the time of this amendment. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Final Staff Report: Rule 4905 January 22, 2015 

10 Final Staff Report with Appendices 

For Amendments to Rule 4905

Emissions Fee Option 

To address concerns from manufacturers, the District added an option to allow 

manufacturers to pay a per unit emissions fee for units sold in the Valley that meet the 

current emission limits but do not meet the amended emission limits. 

To help minimize unfair competitive disadvantage for manufacturers that will provide 

compliant units to the San Joaquin Valley, the amendments allow the sale of noncompliant units during the initial implementation period (36-months) in exchange for the 

payment of an emissions fee for each non-compliant unit sold. This allowance is 

necessary to ensure adequate supply for the expected demand for new units in the San 

Joaquin Valley. However, the emissions fee is set at a level to provide a financial 

disincentive for continued sale of non-compliant units as follows: 

It is estimated that the retail value for non-compliant units will be approximately $150 

less for non-condensing units and $200 less for condensing units. One way to 

disincentivize the sale of non-compliant units would have been to set the emissions fees 

at this price differential. However, to encourage manufacturers to produce compliant 

units with lower emissions the emissions fees include an additional surcharge of $75 for 

non-condensing units and $90 for condensing units. This surcharge equates to the 

incentive rebate currently provided by South Coast AQMD and is expected to put the 

Valley in a more favorable position for receiving compliant units. Therefore, the 

emissions fees are set to $225 for each non-condensing unit and $290 for each 

condensing unit. 

Section 5.4 was added to Rule 4905 with the following language: 

5.4 Emissions Fee Option 

 Any manufacturer of units regulated by this rule may elect to pay a per unit 

emissions fee of $290 for each condensing furnace and $225 for each 

non-condensing or manufactured home furnace distributed or sold into the 

San Joaquin Valley in lieu of meeting the 14 ng/J emission limit in Table 1 

of this rule, provided the NOx emission rate is less than or equal to 40 

ng/J. A manufacturer may elect to pay the per unit emissions fee for a 

time period of no more than 36 months after the applicable compliance 

date in Table 1. A manufacturer shall submit a compliance plan for each 

12-month time period after the applicable compliance date during which 

the manufacturer elects to pay the emissions fee in lieu of meeting the 

NOx emission limit. 

5.4.1 Any manufacturer electing to comply using this emissions fee 

option shall submit to the APCO a compliance plan no later than 30 

days prior to the applicable compliance date in Table 1. The 

compliance plan shall include the following: 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Final Staff Report: Rule 4905 January 22, 2015 

11 Final Staff Report with Appendices 

For Amendments to Rule 4905

5.4.1.1 A letter with the name of the manufacturer requesting the 

emissions fee option signed by a responsible official 

identifying the unit type and the 12-month emissions fee 

option compliance period that the emissions fees cover. 

5.4.1.2 An estimate of the quantity of applicable units to be 

distributed or sold into the San Joaquin Valley Air Basin 

during the emissions fee option compliance period and 

supporting documentation. The estimate shall be based on 

total distribution and sales records or invoices of

condensing, non-condensing, weatherized or mobile home 

fan-type central furnaces that were distributed or sold into 

the San Joaquin Valley Air Basin during the 12-month 

period of July 1 to June 30 prior to the applicable

compliance date, along with supporting documentation. 

5.4.2 The manufacturer shall submit a report to the APCO, signed by the 

responsible official for the manufacturer, identifying by model 

number the quantity of applicable units actually distributed or sold 

into the San Joaquin Valley Air Basin during the applicable 12-

month emissions fee option compliance period and a check for 

payment of emissions fees for those units. The report and payment 

of emissions fees must be submitted to the APCO no later than 

thirty (30) days after the end of each 12-month emissions fee option 

compliance period. 

At the end of each 12 month emissions fee option compliance period, the number of 

units distributed or sold into the District will be reconciled and the manufacturer will pay 

fees for each noncompliant unit sold under the emissions fee option. 

Units Installed in Manufactured Homes 

The District examined whether other air districts regulate units installed in manufactured 

homes and found that until 2009 these units were not regulated in any of the air districts, 

including SCAQMD, Bay Area Air Quality Management District (BAAQMD), Sacramento 

Metropolitan Air Quality Management District (SMAQMD) and Ventura County Air 

Pollution Control District (VCAPCD). SCAQMD added requirements during the 2009 

amendment of Rule 1111 for units installed in manufactured homes to meet a NOx 

emission limit of 40 ng/J, effective October 1, 2012, and an emission limit of 14 ng/J, 

effective October 2018. Most of the basic technology is the same for residential units 

and units installed in manufactured homes, but there are significant differences in 

configuration, sizing, and air supply between the two unit types. Even so, SCAQMD 

added the new requirements because units installed in manufactured homes are capable 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Final Staff Report: Rule 4905 January 22, 2015 

12 Final Staff Report with Appendices 

For Amendments to Rule 4905

of complying with the 40 ng/J NOx emission limit without additional modifications.15 

Amendments do not allow for a sell-through period for these units in the amended rule, 

because they have already been required in SCAQMD since 2012. Amendments allow 

until October 2018 for manufacturers to develop and commercialize units installed in 

manufactured homes that comply with the amended 14 ng/J NOx emission limit and 

provide for a 300-day sell-through period. 

Weatherized Units 

Amendments address weatherized units as a separate technology, consistent with 

SCAQMD Rule 1111. Conversations with manufacturers and comments from 

stakeholders indicated that some of the manufacturers produce weatherized units using 

the same components and technology as non-weatherized units, while others produce 

them as a separate unit type, utilizing different components than non-weatherized units. 

Because some manufacturers produce weatherized units using different components 

and technology as non-weatherized units, some of the manufacturers have requested 

additional time to commercialize weatherized units that comply with the amended 14 

ng/J NOx emission limit. Amendments allow until October 1, 2016 for manufacturers to 

comply with the new 14 ng/J NOx emission limit, with a sell-through period until July 27, 

2017. These compliance deadlines are consistent with SCAQMD Rule 1111. 

Section 6.0—Administrative Requirements 

Amendments revised the labeling requirements for clarity and added a new requirement 

to accompany the amended emission limits. The amended labeling requirements take 

effect on and after the applicable compliance dates in Table 1, and require 

manufacturers to display the heat input capacity or cooling capacity, the applicable NOx 

emission limit, and the date of manufacture or date code on the shipping container and 

rating plate of the unit. The amended labeling requirements ensure compliance with the 

multiple amended emission limits and the sell-through period requirements and align the 

requirements of Rule 4905 with those of SCAQMD Rule 1111. 

Amendments clarify the testing requirements of Section 6.2.1 by specifying that each 

natural gas-fired, fan-type central furnace model must be tested according to the 

requirements, rather than each unit. 

Section 7.0—Compliance Schedule 

Section 7.0 (Compliance Schedule) was removed to eliminate redundancy. The 

compliance schedule is already specified in Sections 5.0 (Requirements) and 6.0 

(Administrative Requirements). 

 

15 SCAQMD. (2009, November 6). Final Staff Report with Socioeconomic Impact Assessment. Retrieved 9/16/14 

from http://www3.aqmd.gov/hb/2009/November/091130a.htm. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Final Staff Report: Rule 4905 January 22, 2015 

13 Final Staff Report with Appendices 

For Amendments to Rule 4905

IV. SUPPORTING ANALYSES 

A. Global Climate Change and Greenhouse Gases 

The California Global Warming Solutions Act of 2006 (AB 32) created a comprehensive, 

multi-year program to reduce greenhouse gas (GHG) emissions in California, with the 

overall goal of restoring emissions to 1990 levels by the year 2020. ARB and the 

Legislature are developing policies and programs to implement AB 32. The District 

believes that the evidence and the rationale that climate change is occurring is 

compelling and convincing. In addition to the long-term consequences of climate 

change, the District is concerned with the potential ramifications of more moderate but 

imminent changes in weather patterns. The Valley depends heavily on agriculture for 

its economy and has developed agricultural practices based on the last several decades 

of weather patterns. Unanticipated and large fluctuations in these patterns could have a 

devastating effect on the Valley’s economy. 

While there are many win-win strategies that can reduce both GHG and criteria/toxic 

pollutant emissions, when faced with situations that involve tradeoffs between the two, 

District staff believes that the more immediate public health concerns that may arise 

from an increase in criteria or toxic pollutant emissions should take precedence. The 

District’s Governing Board adopted the Climate Change Action Plan (CCAP) in August 

2008. For California Environmental Quality Act (CEQA) requirements, one of the goals 

of the CCAP is to establish District processes for assessing the significance of 

greenhouse gas impacts. The District has developed a policy and guidance for 

addressing greenhouse gases under CEQA. 

B. Health Benefits 

The District is a public health agency whose mission is to improve the health and quality 

of life for all Valley residents through efficient, effective and entrepreneurial air quality 

management strategies. The District periodically compiles attainment plans to identify 

individual regulations and other strategies that will achieve the emissions reductions 

needed for the Valley to meet federal health-based air quality standards (National 

Ambient Air Quality Standards, or NAAQS). Guided by its Health-Risk Reduction 

Strategy, the District develops and implements both attainment plans and regulations to 

attain the NAAQS in the quickest, most health-protective, and most cost-effective 

manner. Amendments to Rule 4905 are one component of this overall control strategy. 

Since this rule amendment reduces NOx, it benefits public health by contributing to 

improved ozone and PM2.5 air quality. 

C. Emission Reduction Analysis 

As presented in the 2012 PM2.5 Plan, the annual NOx emissions from the source 

category currently subject to Rule 4905 are expected to be 2.54 tons per day (tpd) in 

2017. The District did not make a specific emission reduction commitment for this rule 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Final Staff Report: Rule 4905 January 22, 2015 

14 Final Staff Report with Appendices 

For Amendments to Rule 4905

amendment in that plan in lieu of conducting a more thorough emission reduction 

analysis in this rule amendment. 

Amendments lower the allowed NOx emission rates by 65% for new units sold in the 

San Joaquin Valley. This will result in approximately 2.10 tpd NOx emission reductions 

upon full turnover of existing units in 2036, reflecting a greater than 50% reduction from 

projected emissions without the reductions achieved by amendments. The complete 

emission reduction analysis is presented in Appendix B of this Final Staff Report. 

D. Cost Effectiveness Analysis 

Pursuant to California Health & Safety Code (CH&SC) Section 40920.6(a), the District 

has prepared a cost effectiveness analysis to analyze the economic feasibility of the 

rule amendments. The estimated cost effectiveness for implementing the amendments 

for natural gas-fired, fan type central furnaces is estimated to range from $30,598 to 

$40,808 per ton of NOx emission reductions. The differential cost to purchase a 14 ng/J 

compliant unit is estimated to range from $160.12 to $213.49, making these 

amendments cost effective. The complete analysis is presented in Appendix C of this 

Final Staff Report. 

E. Socioeconomic Analysis 

Pursuant to CH&SC 40728.5(a), “Whenever a district intends to propose the adoption, 

amendment, or repeal of a rule or regulation that will significantly affect air quality or 

emissions limitations, that agency shall, to the extent data are available, perform an 

assessment of the socioeconomic impacts of the adoption, amendment, or repeal of the 

rule or regulation.” No significant socioeconomic impacts are expected from the rule 

amendments. The complete socioeconomic analysis is presented in Appendix D of this 

Final Staff Report. 

F. Rule Consistency Analysis 

Pursuant to CH&SC Section 40727.2, the District prepared a rule consistency analysis, 

comparing the elements of the amendments with the corresponding elements of other 

District rules and federal regulations. The District found that none of the amendments 

conflict with other District rules, or federal rules, regulations, or policies covering similar 

stationary sources. The complete rule consistency analysis is presented in Appendix E 

of this Final Staff Report. 

G. CEQA 

According to the California Environmental Quality Act (CEQA) statues and pursuant to 

Section 15061 of the CEQA Guidelines, the District investigated the possible 

environmental impacts of the amendments to Rule 4905. Based on the District’s 

investigation and lack of evidence to the contrary, the District has concluded that the 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Final Staff Report: Rule 4905 January 22, 2015 

15 Final Staff Report with Appendices 

For Amendments to Rule 4905

rule amendments will not have any significant adverse effects on the environment. As 

such, the District finds that the rule amendments do not constitute a project under the 

provisions of the California Environmental Quality Act of 1970 (CEQA). Furthermore, 

the rule amendments are exempt per the general rule that CEQA applies only to 

projects which have the potential for causing a significant effect on the environment 

(CEQA Guidelines §15061 (b)(3)). Therefore pursuant to Section 15062 of the CEQA 

Guidelines, Staff filed a Notice of Exemption upon Governing Board approval of 

amendments to Rule 4905. 

V. RULE DEVELOPMENT PROCESS 

A. Public Workshop for Rule 4905 

The District hosted a public workshop to present draft amendments and receive public 

comments on October 16, 2014. The draft rule and staff report were made available for 

the public workshop. The public workshop was followed by a two-week public comment 

period ending at 5:00 PM on October 30, 2014. All significant comments received 

before the comment period deadline were reviewed and incorporated into the proposed 

rule, staff report, and appendices as appropriate. 

B. Public Hearing for Rule 4905 

In accordance with CH&SC Section 40725, the proposed amendments to Rule 4905 

and the final draft staff report were publicly noticed and made available prior to the 

December 18, 2014 Governing Board public hearing to consider adoption of the 

proposed rule amendments. The public was invited to provide comments to District 

Governing Board members during the public hearing. At the public hearing the 

Governing Board made a motion to postpone the adoption of the rule until the next 

regularly scheduled Governing Board public hearing meeting, on January 22, 2015. 

Because significant changes were made to the proposed rule from the version made 

available on November 18, 2014 for public review and comment the District published a 

new version of the rule in accordance with CH&SC Section 40725 requirements prior to 

the January 22, 2015 Governing Board public hearing to consider adoption of the 

proposed rule amendments. The public was again invited to provide comments to the 

District Governing Board at the public hearing on January 22, 2015. 

 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Final Staff Report: Rule 4905 January 22, 2015 

16 Final Staff Report with Appendices 

For Amendments to Rule 4905

This page intentionally blank. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix A: Comments and Responses January 22, 2015 

A - 1 Final Staff Report with Appendices 

 For Amendments to Rule 4905 

APPENDIX A 

Summary of Significant Comments and Responses 

For Amendments to Rule 4905 

January 22, 2015 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix A: Comments and Responses January 22, 2015 

A - 2 Final Staff Report with Appendices 

For Amendments to Rule 4905 

This page intentionally blank. 

 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix A: Comments and Responses January 22, 2015 

A - 3 Final Staff Report with Appendices 

For Amendments to Rule 4905 

SUMMARY OF SIGNIFICANT COMMENTS 

RULE 4905 (NATURAL GAS-FIRED, FAN-TYPE RESIDENTIAL CENTRAL 

FURNACES) 

PROPOSED RULE PACKAGE – January 22, 2015 

The rule package for proposed amendments to Rule 4905 (Natural Gas-Fired, FanType Residential Central Furnaces) was heard before the District’s Governing Board at 

a public hearing on January 22, 2015. The following is a summary of comments 

received at the public hearing. 

EPA REGION IX COMMENTS: 

1. COMMENT: The proposed addition of provisions allowing fee payment in lieu of 

compliance with emission limits (Section 5.4) undermines Rule 4905’s 

enforceability and thus limits our ability to rely on it for SIP emission reduction 

credit in accordance with long-standing national policy on economic incentive 

programs (EIPs) and other non-traditional emission reduction measures (see, 

e.g., Improving Air Quality with Economic Incentive Programs, EPA-452/R-01-

001, January 2001).

RESPONSE: The emissions fee option is only allowed in the first three years of 

implementation, while projected emission reductions are based on the 20 year 

period to reach full turnover of existing units. The District expects compliant units 

to be available by the compliance dates and manufacturer participation in the 

emissions fee option will be minimal. 

2. COMMENT: To clarify the impact of the proposed rule revisions, we request that 

the District clarify, in the associated staff report, the calculated cost of NOx 

reductions ($/ton) based on the fee included in Section 5.4 in the revised draft of 

Rule 4905.

RESPONSE: The District has included sufficient information in the Staff Report 

regarding the cost effectiveness of implementing the proposed amendments. 

ARB COMMENTS: 

A comment letter was not received from ARB. 

PUBLIC COMMENTS: 

Comments were received from the following: 

Air-Conditioning, Heating, & Refrigeration Institute (AHRI) 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix A: Comments and Responses January 22, 2015 

A - 4 Final Staff Report with Appendices 

For Amendments to Rule 4905 

1. COMMENT: The emissions fee should be $150-$200 consistent with the South 

Coast Air Quality Management District’s (SCAQMD) Rule 1111, because in 

concept, the fee in the SCAQMD rule puts compliant and noncompliant units on 

an approximate equal cost base. (AHRI) 

RESPONSE: The proposed emissions fee is designed to provide an advantage 

to manufacturers that produce compliant units while still offering an avenue for 

manufacturers of noncompliant units to offer products while ramping up 

production of compliant units during the initial implementation period. 

 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix A: Comments and Responses January 22, 2015 

A - 5 Final Staff Report with Appendices 

For Amendments to Rule 4905 

SUMMARY OF SIGNIFICANT COMMENTS 

FOR PROPOSED AMENDMENTS TO RULE 4905 (NATURAL GAS-FIRED, FANTYPE RESIDENTIAL CENTRAL FURNACES) 

PROPOSED RULE PACKAGE – December 18, 2014 

The rule package for proposed amendments to Rule 4905 (Natural Gas-Fired, FanType Residential Central Furnaces) was heard before the District’s Governing Board at 

a public hearing on December 18, 2014. The following is a summary of comments 

received at the public hearing. 

EPA REGION IX COMMENTS: 

No verbal comments were received from EPA at the public hearing. 

ARB COMMENTS: 

No verbal comments were received from ARB at the public hearing. 

PUBLIC COMMENTS: 

Comments were received from the following: 

Southern California Gas Company (SCGC) 

1. COMMENT: We appreciate the District’s support in obtaining the research and 

development funding for the technology assessment. We also appreciate the 

District making proposed Rule 4905 consistent with South Coast Air Quality 

Management District (SCAQMD) Rule 1111 and we support the proposed rule 

amendments. (SCGC)

RESPONSE: The District recognizes and appreciates efforts on the part of 

SCGC in developing new technology and participating in the rule amendment 

process for proposed Rule 4905. 

 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix A: Comments and Responses January 22, 2015 

A - 6 Final Staff Report with Appendices 

For Amendments to Rule 4905 

SUMMARY OF SIGNIFICANT COMMENTS 

FOR PROPOSED AMENDMENTS TO RULE 4905 (NATURAL GAS-FIRED, FANTYPE RESIDENTIAL CENTRAL FURNACES) 

PROPOSED RULE PACKAGE – November 18, 2014 

The rule package for proposed amendments to Rule 4905 (Natural Gas-Fired, FanType Residential Central Furnaces) was made available for public review and comment 

by the San Joaquin Valley Unified Air Pollution Control District (District) on November 

18, 2014. Summaries of significant comments received during the public comment 

period are summarized below. 

EPA REGION IX COMMENTS: 

A comment letter was not received from EPA. 

ARB COMMENTS: 

A comment letter was not received from ARB. 

PUBLIC COMMENTS: 

Comments were received from the following: 

Air-Conditioning, Heating, & Refrigeration Institute (AHRI) 

Goodman Global, Inc. (Goodman)

1. COMMENT: The District should revise Proposed Rule 4905 in one or both of the 

following ways:

• Add an emissions fee option to Proposed Rule 4905.

• Extend the compliance deadlines in Proposed Rule 4905 by one year to allow 

additional time for manufacturers to develop compliant units and plan 

inventory positions. (AHRI, Goodman)

RESPONSE: The compliance deadlines and 300-day sell-through period within 

Proposed Rule 4905 are consistent with those recently adopted by SCAQMD. It 

is expected that new units will be available by the proposed compliance 

deadlines. To satisfy plan commitments and provide for regulatory consistency 

in California, the District will not extend the proposed amendments an additional 

year; however, to address the concerns presented, the District will consider 

adding an emissions fee option to Proposed Rule 4905. This additional option 

will be presented to the Governing Board at the Public Hearing on December 18, 

2014. If the Board approves of adding an emissions fee option to Rule 4905, the 

District will return to the Board with updated amendments for consideration in 

early 2015.

 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix A: Comments and Responses January 22, 2015 

A - 7 Final Staff Report with Appendices 

For Amendments to Rule 4905 

SUMMARY OF SIGNIFICANT COMMENTS 

FOR DRAFT AMENDMENTS TO RULE 4905 

(NATURAL GAS-FIRED, FAN TYPE RESIDENTIAL CENTRAL FURNACES) 

PUBLIC WORKSHOP – OCTOBER 16, 2014 

The San Joaquin Valley Unified Air Pollution Control District (District) held a public 

workshop to present, discuss, and hear comments on the draft amendments to Rule 

4905 and draft staff report on October 16, 2014. Summaries of significant comments 

received during the public workshop and the associated two-week commenting period 

following the workshop are summarized below. 

EPA REGION IX COMMENTS: 

3. COMMENT: Clarify if all units or only reference units from the manufacturer 

should be tested and certified under Section 6.2.1.

RESPONSE: Clarifying language has been added to section 6.2.1. See the 

Proposed Rule and Final Draft Staff Report for these changes. 

4. COMMENT: Correct the typographic error referencing ARB Method 100.1 in 

section 6.2.2.

RESPONSE: The reference to CARB Method 100.1 in Section 6.2.2 was 

changed to CARB Method 100, which was approved by EPA June 28, 1997. 

See the Proposed Rule for this change.

5. COMMENT: The District should reduce the sell-through period from the 1 year 

that is currently proposed to a shorter period. Analogous South Coast Rule 1111 

allows for a 300 day sell through period.

RESPONSE: The sell-through period has been amended to be consistent with 

the sell-through period in South Coast Rule 1111. See the Proposed Rule and 

Final Draft Staff Report for these changes. 

ARB COMMENTS:

The District did not receive a comment letter from ARB. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix A: Comments and Responses January 22, 2015 

A - 8 Final Staff Report with Appendices 

For Amendments to Rule 4905 

PUBLIC COMMENTS:

Comments were received from the following: 

 Air-Conditioning, Heating, & Refrigeration Institute (AHRI) 

Ingersoll Rand (IR) 

Southern California Gas Company (SCGC) 

6. COMMENT: What is the price differential between new units and old units based 

on? (SCGC)

RESPONSE: The price differential between new units and old units is based on 

the information used by SCAQMD to set the prices of the emissions fee option 

during the September 5, 2014 amendments to Rule 1111. 

7. COMMENT: The SCAQMD Rule lists the new lower NOx emission limit as 14 

ng/J, and in the Staff Report for September 5, 2014 amendments, states that the 

this is equivalent to 20 ppmv. The District has a ppmv limit of 19.5. This may 

cause problems due to regulatory inconsistency between the two air districts. 

(AHRI, IR, SCGC)

RESPONSE: The NOx limit has been revised in proposed Rule 4905 to 20 ppmv 

for simplicity and consistency. 

8. COMMENT: The District should verify with manufacturers that the labeling 

requirements added to Draft Rule 4905 are feasible to implement. (SCGC)

RESPONSE: The labeling requirements match those in SCAQMD Rule 1111, 

which were adopted after extensive meetings with industry representatives and 

public workshops. 

9. COMMENT: The District should add an emissions fee option to proposed Rule 

4905 to allow manufacturers that are unable to commercialize new units to still 

sell non-compliant units in the District. The District should also extend the 

compliance deadlines beyond those in the SCAQMD to allow additional time for 

manufacturers to commercialize new units and respond to the increase in 

production volume. (AHRI, IR) 

RESPONSE: As discussed in the Final Draft Staff Report, the compliance 

deadlines within Proposed Rule 4905 are consistent with the deadlines recently 

adopted by SCAQMD. Additionally, some manufacturers have indicated that 

compliant models are currently ready for sale, and the District expects additional 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix A: Comments and Responses January 22, 2015 

A - 9 Final Staff Report with Appendices 

For Amendments to Rule 4905 

manufacturers to have compliant units available by the compliance deadlines. 

Refer to the Final Draft Staff Report for further details. 

10. COMMENT: The District should address weatherized units as a separate 

category, with a later compliance deadline than non-weatherized units. (AHRI, 

IR) 

RESPONSE: The District amended the Proposed Rule to implement compliance 

dates that are consistent with SCAQMD. Manufacturers of weatherized units 

would have until October 1, 2016, with a sell-through period until July 27, 2017, 

to comply with the proposed 0.0325 lb/MMBtu NOx emission limit. See 

Proposed Rule 4905 and the Final Draft Staff Report for further details. 

 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix A: Comments and Responses January 22, 2015 

A - 10 Final Staff Report with Appendices 

For Amendments to Rule 4905 

This page intentionally blank. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix B: Emission Reduction Analysis January 22, 2015 

B - 1 Final Staff Report with Appendices 

For Amendments to Rule 4905

APPENDIX B 

Emission Reduction Analysis 

For Amendments to Rule 4905 

January 22, 2015 

 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix B: Emission Reduction Analysis January 22, 2015 

B - 2 Final Staff Report with Appendices 

For Amendments to Rule 4905

This page intentionally blank. 

 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix B: Emission Reduction Analysis January 22, 2015 

B - 3 Final Staff Report with Appendices 

For Amendments to Rule 4905

EMISSION REDUCTION ANALYSIS 

FOR AMENDMENTS TO RULE 4905 

I. SUMMARY 

Rule 4905 reduces emissions of oxides of nitrogen (NOx) by establishing NOx 

emissions for natural gas-fired, fan-type residential central furnaces (residential units) 

sold in the San Joaquin Valley (Valley) with a rated heat input capacity of less than 

175,000 British thermal units per hour (Btu/hr), and for combination heating and cooling 

units, a rated cooling capacity less than 65,000 Btu/hr. 

Amendments to Rule 4905 lowered the NOx emission limit for residential units and 

added NOx emission limits for units installed in commercial buildings (commercial units) 

and units installed in manufactured homes. The NOx emission limit for residential units 

was lowered and the applicability expanded to include commercial units and units 

installed in manufactured homes. Because Rule 4905 is a point-of-sale rule, emission 

reductions will be achieved gradually as older units are replaced over the 20 year 

turnover period from 2017 through 2036. 

The District’s 2008 PM2.5 Plan, 2012 PM2.5 Plan, and 2013 Plan for the Revoked 1-

hour Ozone Standard included commitments to amend Rule 4905, but did not specify 

an emission reduction commitment for this rule amendment; therefore, there is no 

comparison between a plan emission reduction commitment and the amended rule 

emissions reduction. The baseline NOx emissions and estimated NOx emission 

reductions for residential and commercial units are summarized in Table B-1 below. 

Table B-1 Summary of Emission Reductions from Natural Gas-Fired, Fan-Type 

Central Furnaces (2036) 

Furnace Category 2036 Baseline NOx 

Emissions Inventory

(tons per day) 

NOx Emission 

Reduction Upon Full 

Turnover in 2036 

(tons per day) 

Percent Reduction 

from Projected 2036 

Baseline (%) 

Residential 3.24 1.61 50.0 

Commercial 0.92 0.48 52.2 

TOTAL 4.16 2.10 50.5 

II. BACKGROUND 

Rule 4905 applies to any person who supplies, sells, offers for sale, installs, or solicits 

the installation of natural gas-fired, fan-type residential central furnaces with a rated 

heat input capacity less than 175,000 Btu/hr, and for combination heating and cooling 

units, a rated cooling capacity less than 65,000 Btu/hr. Units in the applicable size 

range are used in nearly all residences with access to natural gas and the majority of 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix B: Emission Reduction Analysis January 22, 2015 

B - 4 Final Staff Report with Appendices 

For Amendments to Rule 4905

commercial buildings. As demonstrated in this appendix, the 2036 total baseline NOx 

emission inventory for units affected by rule amendments is 4.16 tons per day (tpd). 

The rule amendments lowered the NOx emission limit for residential units to 14 ng/J; 

established a NOx emission limit of 14 ng/J for commercial units; and require units 

installed in manufactured homes to comply with a NOx emission limit of 40 ng/J and 

lower the NOx emission limit for these units to 14 ng/J in 2018. The compliance dates 

for amendments are as follows: 

• February 1, 2015 for units installed in manufactured homes, 

• April 1, 2015 for condensing residential and commercial units, 

• October 1, 2015 for non-condensing residential and commercial units, and 

• October 1, 2018 for the lower NOx emission limit for units installed in 

manufactured homes. 

Manufacturers, distributors, and retailers are allowed a 300-day sell-through period for 

units manufactured prior to the applicable compliance date. Manufacturers that are 

unable to commercialize new units, or that are unable to respond to the increase in 

demand in time for the compliance dates have the option of paying a per unit emissions 

fee for each noncompliant unit sold in the San Joaquin Valley for up to 36 months after 

the applicable compliance date. As a point-of-sale rule, Rule 4905 emission reductions 

will be achieved through attrition as older units are replaced over the 20 year expected 

life-span of the units during the period from 2017 through the end of 2036. 

Units installed in manufactured homes already achieve the amended 40 ng/J NOx limit 

without requiring any modifications1

, but residential and commercial units require new 

control technologies to achieve the amended NOx emission limit of 14 ng/J. Based on 

technology assessment results (see Staff Report), new units will likely exceed the 

amended NOx emission limit of 14 ng/J; however, the District will claim SIP credit for 

emission reductions gained from implementing the amended NOx emission limit of 14 

ng/J. The following section details the assumptions made for the emission reduction 

analysis, and describes the research and equations used to estimate the total NOx 

emission reductions upon full turnover at the end of 2036. 

III. EMISSION REDUCTION ANALYSIS 

A. Assumptions for the Emission Reduction Analysis 

District staff gathered data from District staff reports, plans, and emissions inventory 

methodologies; South Coast Air Quality Management District (SCAQMD) Staff Reports 

from the November 2009 and September 2014 amendments to Rule 11112,3; the 

California Air Resources Board (CARB) emissions inventory4

; a 2009 California 

 

1

 SCAQMD. (2009, November 6). Final Staff Report with Socioeconomic Impact Assessment. Retrieved 

9/16/14 from http://www3.aqmd.gov/hb/2009/November/091130a.htm. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix B: Emission Reduction Analysis January 22, 2015 

B - 5 Final Staff Report with Appendices 

For Amendments to Rule 4905

Residential Appliance Saturation Study prepared by KEMA, Inc. for the California 

Energy Commission (CEC) (KEMA Study) 5; and Pacific Gas and Electric’s (PG&E) 

Commercial Building Survey Report.6

For the purposes of this Emission Reduction Analysis, the following assumptions were 

made: 

1. The emissions inventory category (EIC) used for residential units (610-606-0110-

0000) includes emissions from units installed in manufactured homes. 

2. The KEMA Study accurately estimates the percent of California population 

residing in mobile homes and the percent of mobile homes using natural gas 

heating. These estimates serve as accurate surrogates for the use of natural gas 

in manufactured homes in the Valley. 

According to the KEMA Study, 3.5% of the California population lives in mobile 

homes, and 70% of mobile homes use gas heating. Assuming that all gas 

heating in mobile homes is attributed to furnaces, the fraction of emissions from 

combustion of natural gas for residential space heating in manufactured homes is 

(0.035) x (0.7) = 0.0245 (or 2.45%). 

3. No additional emission reductions will be achieved from units installed in 

manufactured homes because these units are already meeting the 40 ng/J NOx 

emission limit. Although reductions will be achieved from units installed in 

manufactured homes after the amended 14 ng/J NOx emission limit is 

implemented in 2018, these reductions are expected to be insignificant in 

comparison to total reductions; therefore, the District did not analyze these 

reductions and will not claim SIP credit for them. 

4. The EIC used for commercial units (060-020-0110-0000) was calculated by 

assuming that commercial natural gas combustion for space heating is 

attributable to small boilers; however, the PG&E Commercial Building Survey 

 

2

 SCAQMD. (2009, November 6). Final Staff Report with Socioeconomic Impact Assessment. Retrieved 

9/16/14 from http://www3.aqmd.gov/hb/2009/November/091130a.htm. 

3

 SCAQMD. (2014, September 5). Governing Board Agenda Item, September 5, 2014: Amend Rule 1111 

– Reduction of NOx Emissions from Natural-gas-fired, Fan-type Central Furnaces. Retrieved 9/9/14 from 

http://www.aqmd.gov/docs/default-source/Agendas/Governing-Board/2014/2014-sep5-032.pdf?sfvrsn=2. 

4

 CEPAM, Norcal, Version 1.04. Retrieved 9/9/14 from <planning inventory not available to public> 

5

 KEMA, Inc. (Prepared for California Energy Commission). (2010, October). 2009 California Residential 

Appliance Saturation Study. Retrieved 9/17/13 from http://www.energy.ca.gov/2010publications/CEC200-2010-004/CEC-200-2010-004-ES.PDF. 

6

 Pacific Gas and Electric Company. (1999). Commercial Building Survey Report. Retrieved 9/17/13 from 

http://www.pge.com/includes/docs/pdfs/mybusiness/energysavingsrebates/analyzer/buildingreport/ceus_

1999.pdf. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix B: Emission Reduction Analysis January 22, 2015 

B - 6 Final Staff Report with Appendices 

For Amendments to Rule 4905

Report cited in the methodology references gas furnaces as providing the 

majority of commercial space heating. Because the EIC does not separate 

space heating device types, an estimate was needed for the portion of 

commercial natural gas combustion for space heating attributed to gas furnaces. 

The PG&E Commercial Building Survey Report is assumed to accurately 

estimate the total capacity of natural gas combustion attributed to space heating 

from gas furnaces used in commercial buildings in the Valley. The total percent 

of emissions attributed to gas furnaces was obtained by dividing the total heating 

capacity of gas furnaces in the Valley by the total heating capacity of all device 

types in the Valley. 

Total percent of heating capacity from gas furnaces in the valley and 

desert/mountain climate regions: 

= (total gas furnace capacity / total heating capacity of all units) 

= (12,494 MMBtu/ 17,805 MMBtu) = 70.2% 

5. Because the ARB emission inventory only projects up to 2035, an estimate was 

made for NOx emissions from residential and commercial units in 2036. An 

estimated increase in emissions based on the average annual increase during 

the previous five years (2031-2035) was used. 

 

6. The baseline NOx emission factor (EF) for commercial units is the same as the 

baseline NOx EF for residential units because the units are essentially the same; 

therefore, the baseline NOx EF for residential and commercial units is assumed 

to be the current Rule 4905 limit of 40 ng/J. 

7. Based on the amended compliance dates and sell-through periods, the District 

will claim emission reductions starting in 2017. Non-weatherized units are 

expected to make up the vast majority of sales in the District because 

weatherized units are primarily installed in regions with severe weather. The 

emission reduction calculations in this analysis are conservative because the 

non-weatherized units are required to comply with the amended emission limits 

in January and July of 2016 for condensing and non-condensing units, 

respectively. The unclaimed reductions from these units in 2016 will easily 

exceed the reductions that will potentially be claimed early for weatherized units. 

8. Based on research conducted for the 2005 adoption of Rule 4905, the average 

life for applicable units is 20 years. 

9. Five percent (5%) of units are replaced every year for 20 years, with full 

compliance reached at the end of 2036. 

10. The emissions fee option will not impact expected emission reductions. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix B: Emission Reduction Analysis January 22, 2015 

B - 7 Final Staff Report with Appendices 

For Amendments to Rule 4905

B. Baseline NOx Emissions Inventory for Uncontrolled Units in 2036 

The baseline emissions inventories for units used in residential and commercial 

buildings were obtained from CARB’s CEPAM Norcal V. 1.04. The Emission 

Inventory Categories (EIC) for residential and commercial units are 610-606-

0110-0000 and 060-020-0110-0000, respectively. For both categories, the 

emissions in 2036 were estimated using the average growth rate of emissions 

from the previous five years. The total rule baseline emissions inventory for 

uncontrolled units in residential buildings was calculated as follows: 

Baselineresidential total (in 2036) = Baseline residential emissions in 2035 + 

average annual increase in emissions from 

2031-2035 

 = 3.21 tpd (in 2035) + {[3.21 tpd (in 2035) – 3.05

tpd (in 2031)]/5} 

 = 3.24 tpd (in 2036) 

For units used in commercial buildings, the fraction of emissions attributed to 

furnaces was estimated using the PG&E Commercial Building Survey Report. 

As with residential units, the emissions for 2036 were calculated using average 

annual emission increase for the previous five years. The rule baseline 

emissions inventory for uncontrolled units used in commercial buildings was 

calculated as follows: 

 

Baselinecommercial total (in 2036) = Baseline commercial emissions from all 

devices in 2035 + average annual increase in 

emissions for previous five years 

 = 1.30 tpd (in 2035) + {[1.30 tpd (in 2035) - 1.25

tpd (in 2031)]/5} 

 = 1.31 tpd (in 2036) 

Baselinecommercial net = Baseline emissions from furnaces used in 

commercial buildings 

 = (% of heating capacity for gas furnaces in 

Valley) x (Baselinecommercial total) 

 = (70.2%) x (1.31 tpd) 

 = 0.92 tpd (in 2036) 

Baselinetotal = Baselineresidential + Baselinecommercial

 = 3.24 tpd + 0.92 tpd 

 = 4.16 tpd (in 2036) 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix B: Emission Reduction Analysis January 22, 2015 

B - 8 Final Staff Report with Appendices 

For Amendments to Rule 4905

C. Annual Reductions 

The number of units purchased each year is projected to rise continually during 

the turnover period; the District will claim reductions from the replacement of 

units currently in use. Five percent (5%) of the existing units operating in 2017 

will be replaced annually, starting in 2017, with full turnover reached at the end of 

2036. The annual reductions were calculated as follows: 

 

Annual Reductions = (emissions from 5% of units replaced annually, 

starting in 2017) x (reduction in NOx EF) 

 = (net baseline emissions in 2017) x (0.05) x [1-

(14 ng/J/ 40 ng/J)] 

For residential units, the emissions from units installed in manufactured homes 

were estimated using the KEMA California Residential Appliance Saturation 

Study and removed from the baseline because no additional emission reductions 

will be claimed as a result of amendments for these units. The net rule baseline 

emissions inventory for residential units meeting only the current NOx emission 

limit of 0.093 lb/MMBtu (or 55 ppm), with emissions from manufactured homes 

removed, was calculated as follows: 

Baselinemanufactured homes = (Baselineresidential total) x (% population in mobile 

homes) x (% of mobile homes using natural 

gas) 

 = 2.54 tpd (in 2017) x (3.5%) x (70%) 

 = 0.06 tpd (in 2017) 

Baselineresidential net = Baseline emissions from residential units with 

emissions from manufactured homes removed 

 = Baselineresidential total (from CARB emission 

inventory)7 – Baselinemanufactured homes 

 = 2.54 tpd (in 2017) – 0.06 tpd (in 2017) 

 = 2.48 tpd (in 2017) 

The annual reduction in NOx emissions from residential units was calculated as 

follows: 

Annual Reductionsresidential = (Baselineresidential net) x (5% of units replaced 

annually) x (reduction in NOx EF) 

 = (2.48) x (0.05) x [1-(14/40)] 

 = 0.081 tpd 

 

7

 CEPAM, Norcal, Version 1.04. Retrieved 9/9/14 from <planning inventory not available to public> 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix B: Emission Reduction Analysis January 22, 2015 

B - 9 Final Staff Report with Appendices 

For Amendments to Rule 4905

For commercial units, the net baseline emissions were calculated the same way 

as they were for 2036 as follows: 

Baselinecommercial net = Baseline emissions from furnaces used in 

commercial buildings 

 = (% of heating capacity attributed to gas 

furnaces in Valley) x (Baselinecommercial total) 

 = 70.2% x 1.07 tpd (in 2017) 

 = 0.75 tpd (in 2017) 

The annual reduction in NOx emissions from commercial units was calculated as 

follows: 

Annual Reductionscommercial = (Baselinecommercial net) x (5% of units replaced 

annually) x (reduction in NOx EF) 

 = (0.75) x (0.05) x [1-(0.0325 /0.093)] 

 = 0.024 tpd 

The annual reduction in NOx emission from all units was calculated as follows: 

Annual Reductionstotal = (Reductionsresidential + Reductionscommercial) 

 = 0.105 tpd total annual NOx emission 

reductions 

D. Percent Reduction upon Full Turnover of Existing Units at the End of 2036 

The percent reduction upon full turnover at the end of 2036 was calculated by 

dividing the total reductions by the total baseline emission inventory. In this 

case, the baseline inventory includes manufactured homes. While no reductions 

are claimed for these units, they are still included in the plan inventory; therefore, 

the final percent reduced should reflect the percent reduction in emissions from 

the entire source category. The final percent reduction upon full turnover at the 

end of 2036 is calculated as follows: 

Final reductions = (Total annual reductions) x (20 years turnover 

period) 

 = 0.105 tpd/year x 20 years 

 = 2.10 tpd 

Final Percent Reduction = (Final reductions/Baseline emissions in 2036) x 

100% 

 = 2.10 tpd/4.16 tpd x 100% 

 = 50.5% total percent reduction in NOx 

emissions upon full turnover in 2036 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix B: Emission Reduction Analysis January 22, 2015 

B - 10 Final Staff Report with Appendices 

For Amendments to Rule 4905

IV. CONCLUSION 

As a point-of-sale rule, the NOx emission reductions from this rule amendment will 

occur gradually through attrition as older units are replaced between 2017 and 2036. 

The total NOx emission reduction of 2.10 tpd will occur upon full turnover at the end of 

2036. Table B-2 illustrates the cumulative NOx emission reductions over this 20 year 

period. 

Table B-2 NOx Emission Reductions for Five-Year Intervals from 2020-2036 (tpd) 

Year 2021 2026 2031 2036

Current Total NOx Emission 

Inventory 3.47 3.69 3.92 4.16 

Total NOx Emission Reductions 0.53 1.05 1.58 2.10 

NOx Emission Inventory with 

Amendments Implemented 2.94 2.64 2.34 2.06 
SAN JOAQUIN VALLEY AIR POLLUTION CONTROL DISTRICT 

Appendix C: Cost Effectiveness Analysis January 22, 2015 

 

C - 1 Final Staff Report with Appendices 

For Amendments to Rule 4905 

APPENDIX C 

Cost Effectiveness Analysis 

For Amendments to Rule 4905 

January 22, 2015 

 
SAN JOAQUIN VALLEY AIR POLLUTION CONTROL DISTRICT 

Appendix C: Cost Effectiveness Analysis January 22, 2015 

 

C - 2 Final Staff Report with Appendices 

For Amendments to Rule 4905 

This page intentionally blank. 
SAN JOAQUIN VALLEY AIR POLLUTION CONTROL DISTRICT 

Appendix C: Cost Effectiveness Analysis January 22, 2015 

 

C - 3 Final Staff Report with Appendices 

For Amendments to Rule 4905 

COST EFFECTIVENESS ANALYSIS 

FOR AMENDMENTS TO RULE 4905 

I. SUMMARY 

Per California Health and Safety Code (CH&SC) Section 40920.6(a), the San Joaquin 

Valley Air Pollution Control District (District) conducts absolute and incremental cost 

effectiveness analyses of available emission control options to evaluate the economic 

reasonableness of a new rule or rule amendment prior to adoption. A cost effectiveness 

analysis examines the added cost (in dollars per year) of the control technology or 

technique, divided by the emission reductions achieved (in tons per year (tpy)). 

This rule amendment lowered the NOx emission limit to 14 nanograms per joule (ng/J) 

for natural gas-fired, fan-type, residential central furnaces with a rated heat input of less 

than 175,000 British thermal units per hour (Btu/hr), and for combination heating and 

cooling units a rated cooling capacity of less than 65,000 Btu/hr (referenced in this 

document as residential units). Amendments also expanded applicability to include 

units installed in manufactured homes and units installed in commercial buildings 

(commercial units). 

As Rule 4905 is a point-of-sale rule, the amendments require any units supplied, sold, 

or installed in the San Joaquin Valley (Valley) to meet the amended NOx emission limits 

effective on and after the dates specified in Table 1 in the amended Rule (see Staff 

Report). Manufacturers that are unable to commercialize compliant units, or unable to 

meet the increased demand for compliant units before the compliance dates have the 

option of paying a per unit emissions fee for up to 36 months after the applicable 

compliance deadline to sell noncompliant units in the Valley. 

Based on the analysis in this appendix, the absolute cost effectiveness is summarized 

in Table C-1. Incremental cost effectiveness is not applicable to this project. 

Table C-1 Cost Effectiveness Analysis Findings for Amended Rule 4905 

Number of Units 

Affected*

Differential Cost for a 

0.0325 lb/MMBtu (or 20 

ppmv) Compliant Unit

Absolute Cost 

Effectiveness 

($ per ton NOx reduced)

1,252,190 $18.73 to $24.94 $30,598 to $40,808 

*Rule 4905 is point-of-sale; therefore, units will not be replaced immediately, but will instead be replaced 

at the end of the useful life. 

Cost Effectiveness ($/ton) = Compliance Cost ($/year) 

Emission Reductions (ton/year) 
SAN JOAQUIN VALLEY AIR POLLUTION CONTROL DISTRICT 

Appendix C: Cost Effectiveness Analysis January 22, 2015 

 

C - 4 Final Staff Report with Appendices 

For Amendments to Rule 4905 

II. ESTIMATED COMPLIANCE COSTS 

Estimated compliance costs for a rule project can include, but are not limited to, capital 

equipment costs, engineering design costs, additional labor or fuel costs, installation 

costs, and costs incurred from implementing new safety requirements. The District 

does not expect any additional engineering costs, labor costs, installation costs, or costs 

from new safety requirements resulting from this rule amendment. Therefore, 

compliance costs for this rule amendment consist solely of the price differential between 

14 ng/J and 40 ng/J compliant units. 

Units installed in manufactured homes are already in compliance with the amended 

NOx emission limit of 40 ng/J without requiring modifications;1

 therefore, there are no 

costs associated with these amendments. The final cost effectiveness for weatherized 

units and units installed in manufactured homes that comply with the amended 14 ng/J 

NOx emission limit is expected to be similar to that of other unit types; therefore a 

separate cost effectiveness analysis was not performed for these units because cost 

information is not currently available. 

III. ABSOLUTE COST EFFECTIVENESS ANALYSIS 

Absolute cost effectiveness of a control option is additional annual compliance cost, in 

dollars per year, to meet the amended rule’s requirements divided by the emission 

reductions achieved in tons of pollutant reduced per year. This absolute cost 

effectiveness analysis examines the differential cost of a 14 ng/J compliant unit and a 

40 ng/J compliant unit and the emission reductions anticipated from lowering the NOx 

emission limit to 14 ng/J for residential units and adding a 14 ng/J NOx emission limit for 

commercial units. 

A. Assumptions and Formulas 

The following assumptions and formulas were used for calculating the absolute cost 

effectiveness of lowering the NOx emission limit for residential units to 14 ng/J and 

adding this same limit for commercial units. As these sources are not permitted or 

registered, and the new compliant units are not yet commercially available, the number 

of units subject to amendments and the price differential have been estimated using the 

best available data. 

 

1

 SCAQMD. (2009, November 6). Final Staff Report with Socioeconomic Impact Assessment. Retrieved 

9/16/14 from http://www3.aqmd.gov/hb/2009/November/091130a.htm. 
SAN JOAQUIN VALLEY AIR POLLUTION CONTROL DISTRICT 

Appendix C: Cost Effectiveness Analysis January 22, 2015 

 

C - 5 Final Staff Report with Appendices 

For Amendments to Rule 4905 

1. Price Differential (PD):

The estimated price differential for 14 ng/J and 40 ng/J compliant units is taken 

from the SCAQMD Staff Report from the September 2014 amendment to their 

Rule 1111.2 The emissions fee option for SCAQMD, $150 for non-condensing 

units and $200 for condensing units, was set to match the highest estimates of 

the final price increases to consumers for new compliant units.3 

Commercially available units currently range from approximately $800 to $2,500, 

with the largest price difference being between condensing and non-condensing 

units. It is expected that new units will be more efficient than the units they 

replace, which will help mitigate the price increase over the life of the unit. 

The District calculated a cost effectiveness range based on the SCAQMD 

emissions fees, where the low estimate for the price differential was set to the fee 

for non-condensing units and the high estimate was set to the fee for condensing 

units. The $150 to $200 price differential range would represent scenarios where 

either all sales are non-condensing units, at $150 increase to each consumer, or 

all sales are condensing units, at $200 increase to each consumer. Actual sales 

will be some fraction of each unit type, but accurate estimates were not available 

for those sales fractions. Because the final price differentials for both noncondensing and condensing units are expected to be significantly lower than 

$150 and $200, respectively, this cost-effectiveness analysis conservatively 

represents a worst case scenario. 

The SCAQMD emissions fees are assumed to be valued in 2014 dollars. 

Because 2014 is the latest year available in the BLS Inflation Calculator, the 

average annual inflation rate for years 2010-2014 was calculated by taking the 

arithmetic mean of the annual differences in adjusted dollar values of the price 

differential (PD2010, PD2011, PD2012, PD2013, PD2014). The average annual inflation 

rate was used to calculate the low and high estimates for the price differential in 

2017. The low and high estimates for the price differential (PD) in 2017 were 

calculated as follows: 

PD2014 Dollars, Low Estimate = Emissions fee option for noncondensing units sold in SCAQMD 

 = $150 

 

2

 SCAQMD. (2014, September 5). Governing Board Agenda Item, September 5, 2014: Amend Rule 1111 

– Reduction of NOx Emissions from Natural-gas-fired, Fan-type Central Furnaces. Retrieved 9/9/14 from 

http://www.aqmd.gov/docs/default-source/Agendas/Governing-Board/2014/2014-sep5-032.pdf?sfvrsn=2. 

3

 SCAQMD. (2014, September 5). Governing Board Agenda Item, September 5, 2014: Amend Rule 1111 

– Reduction of NOx Emissions from Natural-gas-fired, Fan-type Central Furnaces. Retrieved 9/9/14 from 

http://www.aqmd.gov/docs/default-source/Agendas/Governing-Board/2014/2014-sep5-032.pdf?sfvrsn=2. 
SAN JOAQUIN VALLEY AIR POLLUTION CONTROL DISTRICT 

Appendix C: Cost Effectiveness Analysis January 22, 2015 

 

C - 6 Final Staff Report with Appendices 

For Amendments to Rule 4905 

PD{2010,2011,2012,2013,2014} = Adjusted value of (PD2014 Dollars, Low 

Estimate) in years 2010-2014, based on 

BLS Inflation Calculator

 = {$137.52, $141.86, $144.79, $146.91, 

$150} 

Average Annual Inflation Rate = {[(PD2011/PD2010) + (PD2012/PD2011) + 

(PD2013/PD2012) + (PD2014/PD2013)]/4} – 1 

 = {[(141.86/137.52) + (144.79/141.86) + 

(146.91/144.79) + (150/146.91)]/4} – 1 

 = 0.022 (or 2.2%) 

 

PD2017 Dollars, Low Estimate = (PD2014 Dollars, Low Estimate) x (1 + Average 

annual inflation rate)^3

 = $150 x (1 + 0.022)3

 = $160.12 

PD2014 Dollars, High Estimate = Emissions fee option for condensing 

units sold in SCAQMD 

 = $200 

Because the inflation rates in the BLS Inflation Calculator are independent of the 

dollar amount being adjusted, the Average Annual Inflation Rate calculated 

above is the same for both the high and low price differential estimates. 

Average Annual Inflation Rate = 0.022 (or 2.2%) (same as calculated 

above for the low estimate PD) 

PD2017 Dollars, High Estimate = (PD2014 Dollars, High Estimate) x (1 + Average 

annual inflation rate)^3

 = $200 x (1 + 0.022)3

 = $213.49 

2. Annualized Compliance Cost (ACC) Formula:

The annualized compliance cost (ACC) shows the price differential per year of 

purchasing a new unit over the entire lifespan of the unit. The ACC was 

calculated as follows: 

ACC = Price Differential x Capital Recovery 

Factor (CRF) 
SAN JOAQUIN VALLEY AIR POLLUTION CONTROL DISTRICT 

Appendix C: Cost Effectiveness Analysis January 22, 2015 

 

C - 7 Final Staff Report with Appendices 

For Amendments to Rule 4905 

The capital recovery factor (CRF) is used to convert the price differential into 

equal annual payments over a specified time, at a specified interest rate. The 

CRF was calculated as follows: 

CRF = 

1( ) 1

1( )

+ −

+

n

n

i

i i

 = 

1( )1.0 1

1(1.0 )1.0

20

20

+ −

+

 = 0.117 

Where: 

 i = Interest rate (10%) 

 n = Equipment life (20 years)4

 

3. Total Number of Units: The number of homes in the Valley was obtained from 

the 2010 Census5 for the years 2010-2012. 

Number of homes in 2010 = 1,332,454 

Number of homes in 2011 = 1,336,374 

Number of homes in 2012 = 1,338,667 

The average rate of increase in number of homes was calculated for that 

period by taking the arithmetic mean of the annual rates of increase, and 

used to estimate the number of homes in 2017 as follows: 

Average rate of increase2010-2012 = {[(# of Homes2011/ # of Homes2010) + (# 

of Homes2012/ # of Homes2011)]/2} – 1 

 = {[(1,336,374/1,332,454) + 

(1,338,667/1,336,374)]/2} – 1 

 = 0.0023 (or 0.23 %) 

Number of homes in 2017 = (number of homes in 2012) x (1 + 

average rate of increase in number of 

homes from 2010-2012)^5 

 = 1,338,667 x (1 + 0.0023)5 

 = 1,354,133 homes in 2017 

The estimated number of homes in 2017 was multiplied by the estimated percent 

of homes using gas heating6

 to obtain the number of residential units subject to 

Rule 4905 in the Valley. It was assumed that all homes using gas heating use a 

natural-gas-fired, fan-type central furnace in the applicable size range. The 

 

4 SJVAPCD. (2005, October 20). Adopt Proposed Rule 4905 (Natural Gas-Fired, Fan-type Residential 

Central Furnaces). Retrieved 12/17/13 from 

http://www.valleyair.org/Board_meetings/GB/agenda_minutes/Agenda/2005/2005-Oct-20/Item10/GB_Agenda_2005_Oct_20_Item-10.pdf. 

5

 U.C. Census Bureau (2010). United States Census 2010. Retrieved 12/17/13 from 

http://www.census.gov/2010census/. 

6

 KEMA, Inc. (Prepared for California Energy Commission). (2010, October). 2009 California Residential 

Appliance Saturation Study. Retrieved 9/17/13 from http://www.energy.ca.gov/2010publications/CEC200-2010-004/CEC-200-2010-004-ES.PDF. 
SAN JOAQUIN VALLEY AIR POLLUTION CONTROL DISTRICT 

Appendix C: Cost Effectiveness Analysis January 22, 2015 

 

C - 8 Final Staff Report with Appendices 

For Amendments to Rule 4905 

number of residential units subject to amended Rule 4905 in 2017 was calculated 

as follows: 

Residential units in 2017 = Number of homes in 2017 x percent of 

homes using gas heating 

 = 1,354,133 x (0.71) 

 = 961,434 homes subject to Rule 4905 in 

2017 

The number of commercial units was estimated by multiplying the number of 

residential units by the ratio of emissions from commercial units to residential 

units. The emissions were taken from Appendix B of this Final Staff Report. It is 

assumed that commercial units subject to Rule 4905 are, on average, the same 

size as residential units, and the usage patterns are similar. The number of 

commercial units subject to amended Rule 4905 in 2017 was calculated as 

follows: 

Commercial units in 2017 = Number of residential units subject to 

amended Rule 4905 in 2017 x 

(emissions from commercial 

units/emissions from residential units) 

 = 961,434 x (0.75/2.48) 

 = 290,756 

The total number of residential and commercial units subject to amended Rule 

4905 in 2017 was calculated as follows: 

Total number of units = Residential units in 2017 + Commercial 

units in 2017 

 = 961,434 + 290,756 

 = 1,252,190 units subject to amended 

Rule 4905 in 2017 

4. Total Annualized Cost (TAC) Formula:

The total annualized cost (TAC) shows the total annual cost of replacing all 

applicable units over the lifetime of those units. The TAC was calculated as 

follows: 

TAC = (ACC) x (Total Number of Units) 

 
SAN JOAQUIN VALLEY AIR POLLUTION CONTROL DISTRICT 

Appendix C: Cost Effectiveness Analysis January 22, 2015 

 

C - 9 Final Staff Report with Appendices 

For Amendments to Rule 4905 

5. Total Emission Reductions: The total emission reductions upon full turnover of 

existing units in 2036 were calculated based on the analysis in Appendix B as 

follows: 

Total Reductionstpd = 2.10 tons per day in 2036 (from 

Appendix B) 

Total Reductionstpy = (Total Reductionstpd) x 365 days/year 

 = 2.10 tpd x 365 days/year 

 = 766.5 tons per year 

6. Absolute Cost Effectiveness (ACE) Formula:

The absolute cost effectiveness, as defined above, is the total annual cost of 

replacing all applicable units, in dollars per year, divided by the total annual 

emission reductions upon full turnover of existing units. The ACE was calculated 

as follows: 

ACE = (TAC) / (Total Emission Reductions) 

B. Annualized Compliance Cost Calculations

ACC = Price Differential x CRF 

 

ACCLow Estimate = $160.12 x 0.117 

 = $18.73 (low estimate) 

ACCHigh Estimate = $213.49 x 0.117 

 = $24.98 (high estimate) 

C. Total Annualized Cost (TAC) Calculations

TAC = (ACC) x (Total Number of Units) 

 

TACLow Estimate = $18.73 x 1,252,190 

 = $23,453,518.70 (low estimate) 

 

TACHigh Estimate = $24.94 x 1,252,190 

 = $31,229,618.60 (high estimate) 

D. Absolute Cost Effectiveness (ACE) Calculations 

ACE = (TAC) / (Total Emission Reductions) 

 
SAN JOAQUIN VALLEY AIR POLLUTION CONTROL DISTRICT 

Appendix C: Cost Effectiveness Analysis January 22, 2015 

 

C - 10 Final Staff Report with Appendices 

For Amendments to Rule 4905 

ACELow Estimate = $23,453,518.70 / 766.5 tpy 

 = $30,598.20 per ton of NOx reduced (low 

estimate) 

ACEHigh Estimate = $31,279,706.20 / 773.8 tpy 

 = $40,808.49 per ton of NOx reduced 

(high estimate) 

IV. INCREMENTAL COST EFFECTIVENESS ANALYSIS

The incremental cost effectiveness is the difference in cost between successively more 

effective controls divided by the additional emission reductions achieved. The amended 

NOx emission limit is considered the lowest feasible achievable NOx emission limit. An 

incremental cost effectiveness analysis is not applicable to this project.

V. CONCLUSION 

The additional cost for a 0.0325 lb/MMBtu (or 20 ppmv) compliant unit is expected to 

range from $160.12 to $213.49 in 2017. The differential cost is distributed over the 20 

year lifetime of the unit, which reduces the financial impact for stakeholders. Also, the 

absolute cost effectiveness is estimated to range from $30,598.20 to $40,808.49 per ton 

of NOx reduced. Therefore, lowering the NOx emission limit to 0.0325 lb/MMBtu (or 20 

ppmv) for natural gas-fired, fan-type central furnaces in this size range and expanding 

rule applicability to include commercial units and units installed in manufactured homes 

is a cost effective and economically reasonable rule amendment. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix D: Socioeconomic Analysis January 22, 2015 

D - 1 Final Staff Report with Appendices 

For Amendments to Rule 4905 

APPENDIX D 

Socioeconomic Analysis 

For Amendments to Rule 4905 

January 22, 2015 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix D: Socioeconomic Analysis January 22, 2015 

 

D - 2 Final Staff Report with Appendices 

For Amendments to Rule 4905 

This page intentionally blank. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix D: Socioeconomic Analysis January 22, 2015 

 

D - 3 Final Staff Report with Appendices 

For Amendments to Rule 4905 

SOCIOECONOMIC ANALYSIS 

FOR AMENDMENTS TO RULE 4905 

I. INTRODUCTION 

Pursuant to California Health and Safety Code (CH&SC) Section 40728.5 as well as the 

2011 Economic Analysis Process Recommendations,

1

 the San Joaquin Valley Air 

Pollution Control District (District) conducts a socioeconomic analysis of a rule or rule 

amendment that will significantly affect air quality or emission limitations prior to rule 

adoption. A socioeconomic analysis examines how a rule project may impact 

industries, businesses, employment rates, and the economy in the San Joaquin Valley 

(Valley). 

The rule amendments achieve emission reductions by lowering the NOx emission limit 

for natural gas-fired, fan-type residential central furnaces (residential units) with a rated 

heat input of less than 175,000 British thermal units per hour (Btu/hr), and for 

combination heating and cooling units, a rated cooling capacity of less than 65,000 

Btu/hr to 14 ng/J. Amendments also expanded applicability to include units installed in 

commercial buildings (commercial units) and units installed in manufactured homes. 

 

The CH&SC requires discussion of the necessity of adopting, amending, or repealing a 

rule to attain state and federal ambient air quality standards; this requirement is met 

through the discussion in the body of the Final Staff Report. The other five CH&SC 

requirements for a socioeconomic analysis are satisfied through this appendix, which 

examines the following items: 

• Type of industries or businesses affected by the rule amendments 

• Range of probable costs for the rule amendments (full discussion contained in 

Appendix C) 

• Emission reduction potential of the rule amendments (full discussion 

contained in Appendix B) 

• Availability and cost effectiveness of alternatives to the rule amendments 

• How the rule amendments impact the Valley’s employment and economy 

The District also evaluated two additional items in this socioeconomic analysis, per the 

District’s 2011 Economic Analysis Process Recommendations: 

 

1

 San Joaquin Valley Air Pollution Control District (SJVAPCD). (2011, October 20). Enhancements to District 

Economic Analysis of Regulations. Fresno, CA. Retrieved 12/17/13 from 

http://www.valleyair.org/Board_meetings/GB/agenda_minutes/Agenda/2011/October/GB_Agenda_Item_13_Oct_20_

2011.pdf. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix D: Socioeconomic Analysis January 22, 2015 

 

D - 4 Final Staff Report with Appendices 

For Amendments to Rule 4905 

• Costs and socioeconomic impacts from previous versions of the rule 

• Impacts of rule amendments to small businesses, municipalities, and at-risk 

communities 

II. AFFECTED INDUSTRIES AND BUSINESSES 

Natural gas-fired, fan-type central furnaces are utilized in a variety of settings, including, 

but not limited to, the following areas: 

• Residential buildings (houses, apartments, etc.) 

• Small commercial buildings (offices, manufacturing facilities, hotels, restaurants, 

hospitals, educational and religious organizations, etc.) 

• Manufactured homes (mobile homes, etc.) 

End-users of natural gas-fired, fan-type central furnaces will be affected by the rule 

amendments, as they will not be allowed to purchase 40 ng/J compliant units and could 

potentially pay more for 14 ng/J compliant units. 

Manufacturers of natural gas-fired, fan-type central furnaces will be affected by the rule 

amendments, but there are currently no furnace manufacturers in the Valley. There are 

Valley wholesalers, suppliers, and contractors who purchase units from manufacturers 

to sell in the Valley that will be affected by the rule amendments. These businesses will 

no longer be allowed to sell, distribute, or install units meeting a NOx emission limit of 

40 ng/J, unless the manufacturer has paid a per unit emissions fee for each 

noncompliant unit sold into the Valley. In that case, the manufacturer will pay the 

additional cost and Valley businesses will not be affected. 

III. COSTS AND SOCIOECONOMIC IMPACTS FROM PREVIOUS VERSIONS OF 

RULE 4905 

Rule 4905 was adopted in October 2005. These amendments represent the second 

generation of this rule. In order to account for the cumulative impact of multiple 

generations of rules on this source category, the 2011 Economic Analysis Process 

Recommendations advises that staff reports include descriptions and cost estimates for 

previous generations of air pollution controls and reference previous socioeconomic 

analyses as each rule is amended. 

The Final Draft Staff Report from the October 20, 2005 adoption of Rule 4905 

determined that there was no significant cost difference between noncompliant units 

and compliant units.2

 

2 SJVAPCD. (2005, October 20). Adopt Proposed Rule 4905 (Natural Gas-Fired, Fan-type Residential 

Central Furnaces). Retrieved 12/17/13 from 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix D: Socioeconomic Analysis January 22, 2015 

 

D - 5 Final Staff Report with Appendices 

For Amendments to Rule 4905 

IV. COSTS AND EMISSION REDUCTION POTENTIAL FROM AMENDED RULE 

4905 

The amendments to Rule 4905 are expected to result in 2.10 tons per day (tpd) of NOx 

emission reductions upon full turnover of existing units(see Appendix B), and the 

average annual cost of a 14 ng/J compliant unit is expected to range from $18.73 to 

$24.94 per year (see Appendix C). 

V. ALTERNATIVES TO RULE AMENDMENT 

The amended NOx emission limit is considered the lowest achievable NOx emission 

limit in practice. Therefore, there are no alternatives to this rule amendment that would 

be more stringent or achieve additional emissions reductions. 

 

VI. SOCIOECONOMIC IMPACTS 

A socioeconomic impact is an effect on the Valley’s employment or economy due to a 

regulatory action. There are no socioeconomic impacts anticipated for these rule 

amendments because there are no significant impacts to the following three groups that 

could potentially be affected by this rule-amending project: 

• The end-users of units; 

• Manufacturers of units; and 

• Wholesalers, suppliers, and/or contractors who supply or install units. 

End-Users 

Rule 4905 is a point-of-sale rule that does not require end-users to replace existing 

units within a certain time frame; rather, as existing units reach the end of their life and 

the users replace them, they will purchase a unit that meets the amended 14 ng/J NOx 

emission limit, thus ensuring that end-users are not forced to incur additional costs 

when their current units are still operable. The price differential between 40 ng/J and 14 

ng/J compliant units is expected to range from $160.12 to $213.49 in 2017. This price 

increase is relatively minor when compared to the total cost of approximately $800 to 

$2,500, with most units costing $1,000 to $1,500. New units are also expected to be 

more efficient than the units they replace, which will help mitigate the price increase 

over the life of the unit. 

Manufacturers 

Manufacturers build natural gas-fired, fan-type central furnaces and sell them to 

wholesalers, suppliers, or contractors for distribution to the end-users. These rule 

 

http://www.valleyair.org/Board_meetings/GB/agenda_minutes/Agenda/2005/2005-Oct-20/Item10/GB_Agenda_2005_Oct_20_Item-10.pdf. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix D: Socioeconomic Analysis January 22, 2015 

 

D - 6 Final Staff Report with Appendices 

For Amendments to Rule 4905 

amendments will have a minimal impact to furnace manufacturers, because any 

additional costs to manufacture the 14 ng/J compliant units will be passed on to the 

consumer. Manufacturers that are unable to commercialize new units before the 

compliance dates or unable to respond to increased demand are able to continue 

selling units in the Valley by paying an emissions fee for each noncompliant unit sold. 

District staff has not identified any furnace manufacturers that have manufacturing 

facilities located in the Valley. During the October 16, 2014 workshop for the draft rule 

amendment, the District solicited information regarding furnace manufacturers in the 

Valley. 

Wholesalers, Suppliers, and/or Contractors 

Wholesalers, suppliers, and contractors are the medium between the manufacturing 

facilities and the end-users, as these parties purchase units from the manufacturers to 

sell and distribute to users. These businesses will no longer be allowed to sell, 

distribute, or install units meeting a NOx emission limit of 40 ng/J. The amendments 

provide these wholesalers and suppliers with a 300-day period after the effective 

compliance dates to sell through existing inventory. Units meeting the NOx emission 

limit of 14 ng/J will be commercially available by the end of 2015. Also, as discussed in 

Appendix C (Cost Effectiveness Analysis), the price differential between a 40 ng/J and 

14 ng/J compliant unit is $160.12 to $213.49. Contractors’, suppliers’, and wholesalers’ 

sales volumes will not be adversely impacted. Profit margins will remain the same as 

the cost will be passed on to the consumer. 

VII. IMPACTS TO SMALL BUSINESSES, MUNICIPALITIES, AND AT-RISK 

COMMUNITIES 

Per the 2011 Economic Analysis Process Recommendations document, District staff is 

advised to evaluate how new rules or rule amendments may impact small businesses, 

municipalities, and at-risk communities where the major employer may respond to 

additional compliance costs by laying off workers. As discussed in Section VI above, 

these rule amendments are not expected to result in any significant socioeconomic 

impacts, nor any decreased employment for small businesses and industries in the 

Valley. As such, municipalities and at-risk communities are not expected to incur any 

economic or employment effects from these rule amendments. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix E: Rule Consistency Analysis January 22, 2015 

E - 1 Final Staff Report with Appendices 

For Amendments to Rule 4905

APPENDIX E 

Rule Consistency Analysis 

For Amendments to Rule 4905 

 

January 22, 2015 

 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix E: Rule Consistency Analysis January 22, 2015 

E - 2 Final Staff Report with Appendices 

For Amendments to Rule 4905

This page intentionally blank. 

 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix E: Rule Consistency Analysis January 22, 2015 

E - 3 Final Staff Report with Appendices 

For Amendments to Rule 4905

RULE CONSISTENCY ANALYSIS 

FOR AMENDMENTS TO RULE 4905 

I. REQUIREMENTS FOR RULE CONSISTENCY ANALYSIS 

Pursuant to Section 40727.2 of the California Health and Safety Code, prior to adopting, 

amending, or repealing a rule or regulation, the District is required to perform a written 

analysis that identifies and compares the air pollution control elements of the rule or 

regulation with corresponding elements of existing or proposed District and United 

States Environmental Protection Agency (EPA) rules, regulations, and guidelines that 

apply to the same source category. The elements analyzed are emission standards, 

monitoring and testing requirements, and recordkeeping and reporting requirements. 

The analysis is discussed in Section II below.

II. RESULTS OF ANALYSIS 

A. District Rules 

There is no other District prohibitory rule or regulation tailored specifically for natural 

gas-fired, fan-type central furnaces (4354 applies to glass melting furnaces). Sources 

could be subject to other District rules including:

 Rule 1020 Definitions 

 Rule 1140 Applicability of Emissions Limits 

 Rule 4301 Fuel Burning Equipment 

 Rule 6150 Enforcement 

The requirements of the rules listed above are not in conflict with, nor are they 

inconsistent with the requirements of amended Rule 4905. 

B. Federal Rules, Regulations, and Policies 

There are no applicable Control Technique Guidelines (CTG), Alternative Control 

Techniques (ACT), New Source Performance Standards (NSPS), National Emission 

Standards for Hazardous Air Pollutants (NESHAP), Best Available Control Technology 

(BACT), or Maximum Achievable Control Technology (MACT) guidelines for natural 

gas-fired, fan-type central furnaces with a rated heat input capacity less than 175,000 

Btu/hr or, for combination heating and cooling units, a rated cooling capacity less than 

65,000 Btu/hr. 

1. Control Technique Guidelines (CTG) 

District review of the EPA CTG list indicates that there is no CTG for natural gasfired, fan-type central furnaces of this size. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix E: Rule Consistency Analysis January 22, 2015 

E - 4 Final Staff Report with Appendices 

For Amendments to Rule 4905

2. EPA Alternative Control Techniques (ACT) Document 

District review of the EPA ACT list indicates that there is no ACT for natural gasfired, fan-type central furnaces of this size. 

3. EPA New Source Performance Standard (NSPS) 

District review of 40 CFR 60 (NSPS) indicates that there is no NSPS for natural 

gas-fired, fan-type central furnaces of this size. 

4. National Emission Standard for Hazardous Air Pollutants (NESHAP) and 

Maximum Achievable Control Technology (MACT) 

District review of 40 CFR 61 (NESHAP) and 40 CFR 63 (MACT) indicates that 

there is no NESHAP or MACT for natural gas-fired, fan-type central furnaces of 

this size. 

5. EPA Best Available Control Technology (BACT) Requirements 

District review of EPA BACT requirements indicates that there are no BACT 

requirements listed for natural gas-fired, fan-type central furnaces of this size. 

6. EPA Policy on Recordkeeping 

EPA has a policy that mandates stationary sources keep and maintain records 

for at least five years; however, as a point-of-sale rule, natural gas-fired, fan-type 

commercial and residential central furnaces of this size are not permitted sources 

and are thus not required to follow specific recordkeeping guidelines. Therefore, 

units subject to Rule 4905 are not subject to EPA’s Policy on Recordkeeping. 

III. CONCLUSION 

Based on the above analysis, District staff found that the amendments to Rule 4905 do 

not conflict with any District or federal rules, regulations, or policies covering similar 

stationary sources.