United States Environmental Protection Agency, Region IX

Air Division

Technical Support Document

For

EPA’s Notice of Proposed Rulemaking

For the

California State Implementation Plan

South Coast Air Quality Management District

Rule 1186, PM10 Emissions from Paved and Unpaved Roads and Livestock 

Operations

Christine Vineyard

August 2, 2011
Agency: South Coast Air Quality Management District

Rule 1186: PM10 Emissions from Paved and Unpaved Roads, and Livestock Operations

SCAQMD Adoption: July 11, 2008

California Air Resources Board (CARB) Submittal: May 17, 2010

EPA Completeness Finding: April 20, 2009

Rule Summary

Rule 1186 controls emissions of particulate matter (PM) from paved and unpaved public roads,

and livestock operations. Under existing Rule 1186, street sweeper manufacturers are required 

to certify their equipment pick up efficiency is at least 80 percent. It has been more than five 

years since any certification testing has been conducted and there was a need to ensure that 

the overall performance of the sweepers can still demonstrated in the event the manufacturer 

changes parts suppliers and/or modifies any sweeper specification from that on the originally 

configured models. The amended rule requires submission of data to demonstrate that the 

sweeper performance has not been affected by these changes and also establishes a process 

that aftermarket parts suppliers may quality to sell replacement parts while maintaining the 

original equipment certification.

Changes from the SIP Rule

The following changes were made to SCAQMD Rule 1186:

(d) Requirements 

(d)(3) – clarified that the use of replacement parts that have been determined by the 

Executive Officer to be substantially similar to the original equipment 

manufacturer (OEM) part is not a violation of this requirement.

(e) Street Sweeper Testing and Certification Procedures

(e)(1)(A)(i) – adds requirement for manufacturers to provide a complete description of 

the equipment’s dust collection system when requesting certification of new 

equipment.

(f) Street Sweeper Performance Characteristics was added to the rule. This new section 

requires:

1. Manufacturers of street sweepers previously certified under the provisions of this 

rule are to submit a complete description of the sweepers dust collection and 

suppression systems as configured during certification testing.

2. A List of the minimum information on the description of dust collection and 

suppression systems that must be provided to the SCAQMD.
3. Manufacturers to notify the SCAQMD for approval prior to substitution of spare parts are in 

order for the sweeper to maintain its certification status.

4. Street sweeper suppliers selling replacement parts to demonstrate the replacement part is 

similar to the original equipment manufacturer part.

5. Entities submitting a plan under paragraphs (f)(3) or (f)(4) are subject to the plan submittal 

requirements and applicable fee under Rule 306.

6. Any plan submitted under (f)(3) and (f)(4) will be approved, conditionally approved, or 

disapproved in writing within 120 days.

Rule Evaluation

a. Rule Stringency – SCAQMD is a serious PM10 nonattainment area and subject to CAA § 189 

PM requirements regarding Reasonably and Best Available Control Measures (RACM and

BACM). The SIP-approved version of this rule was determined to meet the BACM provisions. 

The requirements to insure continued compliance added in this revision further strengthens 

the SIP. 

b. Enforceability – CAA § 110(a)(2)(A) states that regulations submitted to EPA for SIP approval 

must be clear and legally enforceable. The requirements for submission of data on dust 

collections and suppression systems and certification are clear and enforceable. 

c. Anti-Backsliding – CAA § 110(I) and § 193 restrict SIP revisions from relaxing existing 

requirements. The submitted rule 1186 strengthens the SIP rule by requiring that the overall 

performance of the street sweepers can still be demonstrated in the event the manufacturer 

changes parts suppliers and/or modifies any sweeper specification from that on the originally 

configured model. This insures continued effective PM emission controls using certified street 

sweepers. 

Recommendation

The submitted rule strengthens the SIP and fulfills the requirements of enforceability, SIP 

relaxations, and RACM/BACM. Therefore, submitted Rule 1186 should be given full approval.

Attachments

1. SCAQMD Rule 1186 – PM10 Emissions from Paved and Unpaved Roads, and Livestock 

Operations, amended July 11, 2008.

2. SIP-Approved SCAQMD Rule 1186 - PM10 Emissions from Paved and Unpaved Roads, and 

Livestock Operations, adopted 2, 2004.
3. “Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations,” USEPA, May 28, 

1988 (cover only).

4. Staff Report for Proposed Amendments to SCAQMD Rule 1186, PM10 Emissions from Paved 

and Unpaved Roads, and Livestock Operations, July 2008.