January 25, 2011

VIA E-MAIL TO PATRICK AU

Mr. Michael Guzzetta, Manager Rule Evaluation Section Emissions Assessment Branch Stationary Source Division Air Resources Board P.O. Box 2815 Sacramento, CA 95812

Subject: SIP Submittal for Recently Amended Rule 102 (Definitions), Rule 202 (Exemptions to Rule 201), and Rule 370 (Potential to Emit

̶ Limitations for Part 70 Sources), and New Rule 810 (Federal Prevention of Significant Deterioration)

Dear Mr. Guzzetta:

On January 20, 2011, the Santa Barbara County Air Pollution Control District Board of Directors held a public hearing on adopting new Rule 810 (Federal Prevention of Significant Deterioration) and amended Rules 102 (Definitions), 202 (Exemptions to Rule 201), and 370 (Potential to Emit

̶ Limitations for Part 70 Sources). After the public hearing, the Board adopted the new rule and the amended rules. Transmitted with this letter is the adopted new and amended rules for inclusion in California State Implementation Plan (SIP).

The new requirements in Rule 810 and the revised requirements in Rules 102, 202, and 370 are summarized below:

 New Rule 810, Federal Prevention of Deterioration (PSD)

Rule 810 incorporates by reference the federal “Preven tion of Significant Deterioration of Air Quality” rule requirements.

 Amended Rule 102, Definitions

The District adde d a definition for “greenhouse gas” or “greenhouse gases.” In addition, the definition of attainment pollutant has been clarified to exclude greenhouse gases.

 Amended Rule 202, Exemptions to Rule 201

Rule 202.D.2 includes a new provision to ensure prior permit exemptions will continue to apply to sources of GHGs.

 Amended Rule 370, Potential to Emit

̶ Limitations for Part 70 Sources

The District revised definitions for consistency and incl uded the federal GHG threshold for a major source. The amended rule also incorporates the federal definition of GHGs, found in the Part 70 (Title V) regulation (40 CFR 70.2). Other changes were made for improved rule clarity.Page 2 As part of this SIP submittal, please submit a request to EPA on our behalf to withdraw Rule 803, Prevention of Significant Deterioration, for SIP consideration. The re cord indicates that ARB submitted Rule 803 (as adopted April 17, 1997) to EPA for inclusion into the SIP on March 10, 1998.

The District is providing the following to clarify responses to the SIP Completeness Checklist and explain the associated material we are submitting:

1. Reference Checklist Item 3, Complete Copy of th e Referenced Rules The SIP Completeness Checklist requests copies of all referenced ru les, unless previously submitted as part of an earlier SIP submittal. Rules 102, 202, and 370 reference Rules 102, 201, 202, 210, 321, 331, 505, 802, 803, 804, 806, and 1301. Our records indicate that the District has previously submitted all of these rules except Rule 1301 as part of earlier SIP submittals. Records also indicate that:

a. the District withdrew Rule 210, Fees, from SIP consideration (letter dated June 26, 1997), and b. EPA indicated that Rule 210 need not be included in SIP submittals (email of June 24, 2008 from Andy Steckel to Patrick Au).

Hence, the only referenced rule we are submitting rela tive to this checklist item is Rule 1301, Part 70 Operating Permits

̶ General Information, as adopted January 20, 2011.

2. Reference Checklist Item 8, Non-EPA Test Methods Rules 102, 202, and 321 include references to nonEPA test methods. The SIP Completeness Checklist indicates we may need to submit such test methods with this package. Our analysis indicates that many of the test methods and/or procedures have likely been previously submitted to EPA. 1 At this juncture, in lieu of submitting the test methods, we are providing the following table, which identifies 1) where a rule refe rences a non-EPA test method, 2) the test method name/number, and 3) if applicable, where the test method is available on the Internet. 2

Item Rule No., Definition or Section Test Method Internet Website Where the Test Method is Available Other Information

1 102, Gasoline definition Test Method for the Determination of the Reid Vapor Pressure Equivalent Using an Automated Vapor Pressure Test Instrument http://ccr.oal.ca.gov/linkedslice/default.asp?SP=CCR1000&Action=Welcome This test method is found in the California Code of Regulations, Title 13, Division 3, Chapter 5, Article 4, section 2297. 2 102,MultipleChamber Incinerator definition Standard Test Method for Pyrometric Cone Equivalent (PCE) of Fireclay and High Alumina Refractory Materials, ASTM Method C-24. http://www.astm.org/Standa rds/C24.htm

3 102, Organic Solvents Standard Test Method for Distillation Range of Volatile Organic Liquids, ASTM D 1078-05 http://www.astm.org/Standa rds/D1078.htm

4 202, Section U.2.b Standard Test Method for Distillation Range of Volatile Organic Liquids, ASTM D-1078-05 http://www.astm.org/Standa rds/D1078.htm

1 The test methods are likely within other air district rules.
2 Staff will provide the test method(s) upon request.