### July 28, 2010 JamesGoldstene California Air Resources Board 1001"I" Street P.O. Box 2815 

### Sacramento,CA 9581 2 Re: 2009 1 997 8-Hour Ozone ModifiedAir Quality 

### Management Plan (2009 Modified AQMP) andthe 2809 Reasonably Available Control Technology State Implementation Plan (2009 RACTSIP) Dear Mr. Goldstene: The Imperial County Air Pollution Control District (Air District) is formally remitting to you 

### the Final 2009 1997 8-Hour Ozone Modified Air Quality Management Plan (2009 

### Modified AQMP) and the Final 2009 Reasonably Available Control Technolugy State Implementation Plan (2009 RACT SIP) and associated findings for your review, comment and adoption. The Final2009 Modified AQMP and the Final 2009 RACT SIP were adopted by

### the lmperial CountyAir Pollution Control District Board of Directors on July 13, 2010. As a matter of background, the United States Environmental Protection Agency (US EPA) issued a final ruling on December 3, 2009 determining that the Imperial County "Moderaten 8-hour ozone non-attainment area attained the 1997 8-hour National Ambient Air Quality Standard (NAAQS). The determination by US EPA resulted inthe suspension of the requirement of an attainment demonstration, a reasonable further progress plan, contingency measures and other planning requirements for 

### as long as Imperial County continues to attain the 1997 8-hour ozone NAAQS. However, the determination did not constitute a re-designationto attainment under the Clean Air Act (CAA) section 107(d)(3) and as such the classification and designation status for lmperial County remains as "Moderate" non-attainment for the 1997 &hour ozone NAAQS. Therefore, in 

### response to the retained "Moderate" non-attainment status lmperial County prepared and is submitting for CARB approval and remittance to US EPA this 2009 Modified AQMP. The Final2009 ModifiedAQMP includes the following CAA requirements. 1. A growth emissions inventory for Nitrogen Oxides (NOx) 

### and Volatile Organic Compounds (VOC's) (CAA, sections 172(c)(3)and 182(a)(l) 2. New Source Review (CAA, sections 172 (c)(4) and (5);and 182(a)(2)(C))3 Subpart 2 RACTfor VOC's and NOx (CAA, sections 182(b)(2).182(f)) 4. Periodic Inl~eniory (CAA, section 182(a)(3)(A)) 5. Emissions Statement Rule (CAA,section 182(a)(3)(8)) S. Offset Ratio 1.15to 1 (CAA, sections 182(a)(4)and 182(b)(5)) 

### 7. Stage2 Gasoline Vapor Recovery (GVR),(CAA, section 182(b)(3)) The Final2009 ModifiedAQMP fulfills the requirementsas set forth in the CAAfor those areas classified as a "Moderate" non-attainmentforthe 1997 ozone NAAQS. Of the listed CAA requirements contained in the Final

### 2009 Modified AQMP the Subpart 2 RACT for VQC's and 

### NQx has been included in this remittance as its own separate document for consideration and approval. The CAA requires that area classified as "Moderate" or above submit a demonstration that RACT is implemented for all sources subject to Control Technique Guideline (CTG) documents and for major sources ofVOC and NOx that are not subject to a CTG. Therefore the Air District developed and adopted the Final 2009 RACT SIP for CARB approval and remittance to US EPA for consideration and approval. The Final 

### 2009 RACT SIP is a new determination demonstrating that RACT is implemented on all sources subject to a CTG and major sources not subject to a CTG. The Final 

### 2009 RACT SIP provides the follo~ving information as provided for 

### by the US EPA in letters intended as guidance to air districts: 1. A description of how source categories withinthe district were identified as requiring WCT. The description identifies those under a CTG and those that are major nonCTG sources. 

### 2. A section identifying where there are no facilities major or minor within the district subjectto a CTG which clearly makes a negative declaration on those sources. 3. A list of statellocal regulation that implements RACT for those categories needing RACT. Included in the list is the date EPA approved the regulations as fulfilling RACT. 4. Included is a description of the basis for reaching the conclusion that the current regulations fulfill RACT. Supporting documents such as CTGs, Alternative Control Technique guidance (ACTS), Maximum Achievable Control Technology (MACT) standards, New Source Performance Standards (NSPS), California Suggested Control Measures (SCM) and Best Available Retrofit Control Technology (BARCT) determinations, regulations adopted in other districts, and guidance and rules developed by other state and local agencies are identified for reference.5. Although the Air District d~d not choose to use the California Air Pollution Control Officer's Association (CAPCOA's) Potential All Feasible Measures (AFM). EPA guidance indicated that a certification would be required which provided certification that the local regulations were equivalent to AFM as well as a justification that the assumption that the AFM fulfilled RACTwhen adopted in September of 2003. Both documents, the Final 2009 Modified AQMP and the Final 2809 RACT SIP, were developed with the participation and cooperation of stakeholders. Stakeholders included health, environmental and community representatives, industry and transportation agencies. Both State and Federal agencies included the US EPA and the GARB. Enclosedyou will find adisc with the following information: 

### I. The Final2009 1997&Hour Ozone ModifiedAir 

### Quality Management Plan 2. The Final2009 Reasonably Available Control Techniques State Implementation Plan 3. Staff Report. 4. Minute Order (Board Approval) The Imperial County APCD greatly appreciates the cooperative working relationship that CAR6 staff has provided throughout this process. If you have any 

### questions please do not hesitate to contact meat 760482-4606.

~{ad Poiriez Air Pollution ControlOfficer

CC: LynnTerry, Deputy ExecutiveOfficer Karen Magliano,Air Quality Data BranchChief