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 “Prevention of Significant Deterioration of Air Quality” rule 

requirements. 

 Amended Rule 102, Definitions 

The District added 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 included 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 record 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 the Referenced Rules The SIP Completeness Checklist 

requests copies of all referenced rules, 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 relative 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 references 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/linkeds

lice/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.