SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT

Final Supplement to the 24-Hour PM2.5 State Implementation Plan for the South 

Coast Air Basin

February 2015

Executive Officer

Barry R. Wallerstein, D. Env.

Deputy Executive Officer

Planning, Rule Development and Area Sources

Elaine Chang, DrPH

Assistant Deputy Executive Officer

Planning, Rule Development and Area Sources

Philip Fine, Ph.D.

Author: Joseph Cassmassi Planning and Rules Manager

Sang-Mi Lee, Ph.D. Program Supervisor

Kalam Cheung, Ph.D. Air Quality Specialist

Michael Krause Program Supervisor

Reviewed By: Barbara Baird Chief Deputy Counsel

Megan Lorenz Senior Deputy District Counsel
SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT

GOVERNING BOARD

CHAIRMAN: DR. WILLIAM A. BURKE

Speaker of the Assembly Appointee

VICE CHAIR: DENNIS R. YATES

Mayor, City of Chino

Cities Representative, San Bernardino County

MEMBERS:

MICHAEL D. ANTONOVICH

Supervisor, Fifth District

Los Angeles County Representative

BEN BENOIT

Mayor, City of Wildomar

Cities of Riverside County

JOHN J. BENOIT

Supervisor, Fourth District

Riverside County Representative

JOE BUSCAINO

Councilmember, Fifteenth District

City of Los Angeles Representative

MICHAEL A. CACCIOTTI

Councilmember, City of South Pasadena

Cities of Los Angeles County, Eastern Region

JOSEPH K. LYOU, PH.D.

Governor's Appointee

JUDITH MITCHELL

Councilmember, Rolling Hills Estates

Cities of Los Angeles County, Western Region

SHAWN NELSON

Supervisor, Fourth District

Orange County Representative

DR. CLARK E. PARKER, SR.

Senate Rules Committee Appointee

MIGUEL A. PULIDO

Mayor, City of Santa Ana

Cities Representative, Orange County

JANICE RUTHERFORD

Supervisor, Second District

San Bernardino County Representative

EXECUTIVE OFFICER:

BARRY R. WALLERSTEIN, D.Env.
Supplement to 24-hour PM2.5 SIP

Preface February 2015

PREFACE

A version of this Draft Supplement was made available at the SCAQMD Public Information 

Center on December 19, 2014 in accordance with the release of the noticing for the public 

hearings in February 2015 pursuant to the requirements of the Health & Safety Code § 40466. In 

response to comments and suggestions from the staff at U.S. Environmental Protection Agency 

(EPA) and the California Air Resources Board (CARB), some additions and clarifications have 

been included in a January 2015 version of the Draft Supplement that was considered and 

approved by the SCAQMD Governing Board at their February 6, 2015 Board Meeting for 

submission into the 24-hour PM2.5 State Implementation Plan (SIP) for the South Coast Air 

Basin. The additions and clarifications were accepted in this final version (February 2015) that 

will be forwarded to the CARB and subsequently U.S. EPA for approval as part of the California 

SIP.
Supplement to 24-hour PM2.5 SIP

TOC February 2015

TABLE OF CONTENTS

Introduction ...................................................................................................................................1

2012 Air Quality Management Plan ................................................................................................2

U.S. EPA Implementation Guidance for the 2006 24-hour PM2.5 NAAQS ..................................3

Clean Air Act, Title 1, Part D, Subpart 4.........................................................................................3

Air Quality Monitoring Data ...........................................................................................................4

Supplement to the 24-hour PM2.5 SIP ............................................................................................5

2015 Attainment Demonstration..........................................................................................5

Effects of the Drought..........................................................................................................5

Paths Forward ......................................................................................................................6

2015 Transportation Conformity Budgets...........................................................................7

RACM/RACT Analysis.......................................................................................................7

Clean Air Act, Subpart 4, Section 189(e) and Other Precursor Requirements....................7

Control Strategy Commitments ...........................................................................................7

LIST OF ATTACHMENTS 

ATTACHMENT A – Attainment Demonstration of the 24-hour PM2.5 NAAQS for 2015

ATTACHMENT B – Effects of the Drought

ATTACHMENT C – New Transportation Conformity Budgets for 2015

ATTACHMENT D – Updated RACM/RACT Analysis

ATTACHMENT E – Clean Air Act, Subpart 4, Section 189(e) and Other Precursor 

Requirements

ATTACHMENT F – Updated List of Control Strategy Commitments
Supplement to 24-hour PM2.5 SIP

1 February 2015

INTRODUCTION

The Federal Clean Air Act (CAA) requires the United States Environmental Protection Agency 

(U.S. EPA) to develop and enforce regulations to protect the public from airborne contaminants 

known to be hazardous to human health. To do so, the U.S. EPA sets National Ambient Air 

Quality Standards (NAAQS) for “criteria” pollutants, such as particulate matter less than 2.5 

microns (PM2.5), and designates areas in attainment or in non-attainment of the NAAQS. 

According to the CAA, if an area is designated non-attainment, the state is required to submit a 

State Implementation Plan (SIP) to demonstrate how and when the NAAQS will be achieved, 

maintained and enforced. The federal SIP requirements for the South Coast Air Basin (Basin) 

non-attainment area are addressed through Air Quality Management Plans (AQMP) prepared by 

the South Coast Air Quality Management District (SCAQMD) in collaboration with the 

California Air Resources Board (CARB) and the South California Association of Governments 

(SCAG). Required elements of the SIP include:

 Emission Inventory (CAA §172(c)(3))

 Attainment demonstration and modeling (CAA §172(a)(2)(A)) 

 All Reasonably Available Control Measures (RACM) including adoption of 

Reasonably Available Control Technology (RACT) (CAA § 172(c)(1)) 

 Demonstration of Reasonable Further Progress (CAA §172(c)(2))

 New Source Review Program(CAA §172(c)(4) and (5)) 

 Contingency measures (CAA §172(c)(9)) 

 Transportation Control Measures (CAA §108)(e)

On December17, 2006, the U.S. EPA lowered the 24-hour PM2.5 NAAQS from 65 μg/m3to 35 

μg/m3and the South Coast Air Basin was subsequently designated non-attainment for 2006 24-

hour PM2.5 NAAQS on December 14, 2009. U.S. EPA requires the SIP to be submitted no later 

than three years after the designation. To assist in the development of the SIPs to demonstrate 

attainment of the 2006 24-hour PM2.5 NAAQS, the U.S. EPA issued implementation guidance 

in March of 2012. 

The 2012 AQMP was approved by the SCAQMD Governing Board in December 2012, with 

additional amendments approved in February 2013, and was subsequently submitted to CARB 

and the U.S. EPA for inclusion into the SIP. That plan demonstrated projected attainment of the 

2006 24-hour PM2.5 NAAQS by 2014. However, a recent court decision (Nat’l Res. Def. 

Council v. EPA, 706 F.3d 428 (D.C. Cir. 2013)) compels U.S. EPA to evaluate the 24-hour 

PM2.5 SIP under CAA Subpart 4 requirements specific to particulate matter, in addition to the 

general planning provisions of Subpart 1 that were previously used for PM2.5 SIPs. Subpart 4 

provides for an attainment year of 2015 for “moderate” areas, one year later than the attainment 

year in the 2012 AQMP. Furthermore, preliminary ambient air quality data suggests that 
Supplement to 24-hour PM2.5 SIP

2 February 2015

meeting the 2006 24-hour PM2.5 NAAQS by the end of 2014 is not likely, largely due to 

unusually extreme drought conditions in the Basin. Therefore, the purpose of this Supplement to 

the 24-hour PM2.5 SIP for the South Coast Air Basin is to demonstrate attainment of the 2006 

24-hour PM2.5 NAAQS by 2015 as allowed under CAA Subpart 4. In addition, the Supplement 

will update the transportation conformity budgets, RACM/RACT analysis, emission reduction 

commitments submitted in the 2012 AQMP, and other Subpart 4 requirements.

2012 AIR QUALITY MANAGEMENT PLAN

The 2012 AQMP demonstrated attainment of the 2006 24-hour PM2.5 NAAQS (35 μg/m3) with 

successful implementation of all feasible controls and assuming typical weather, demonstrated 

the earliest possible attainment date for the Basin was the end of 2014. 

The 2012 AQMP included the items listed above but, more specifically, the following elements:

 Attainment demonstration of the 2006 24-hour PM2.5 NAAQS for 2014;

 A RACM/RACT analysis;

 2014 transportation conformity budgets; and

 Control strategy including emission reduction commitments with adoption and 

implementation dates 

Since the Governing Board approval of the 2012 AQMP in December 2012 with amendments in 

February 2013, two PM2.5 control measures, BCM-01 (Further Reductions from Residential 

Wood Burning Devices) and BCM-02 (Further Reductions from Open Burning), were adopted in 

the form of amendments to Rules 445 (Wood Burning Devices) and 444 (Open Burning), 

respectively. Together, these amendments generated a total of 11.7 tons of PM2.5 per day 

reductions on an episodic basis. The attainment demonstration relies primarily on emissions 

reductions associated with revisions to Rules 444 and 445. Both of these rule revisions have 

been adopted by SCAQMD and approved by U.S. EPA. (78 FR 59249, September 26, 2013).

The only other emission reduction commitment in the 2012 PM2.5 SIP was control measure 

CMB-01 (Further NOx Reductions from RECLAIM) which was submitted as a contingency 

measure only. This control measure is anticipated to be considered by the SCAQMD Governing 

Board in the first half of 2015. By implementing these control measures, the air quality 

modeling in the 2012 AQMP demonstrated attainment of the 2006 PM2.5 standard in 2014. 

However, as discussed later, unanticipated extreme weather conditions have affected air quality 

making attainment in 2014 unlikely.
Supplement to 24-hour PM2.5 SIP

3 February 2015

U.S. EPA IMPLEMENTATION GUIDANCE FOR THE 2006

24-HOUR PM2.5 NAAQS

In March of 2012, U.S. EPA issued a memorandum to provide guidance regarding the 

development of SIPs required to demonstrate attainment of the 2006 24-hour PM2.5 NAAQS. 

The guidance included a section regarding “overall framework” based on CAA Subpart 1 for 

general nonattainment plan provisions, specifically section 172(a)(2)(A) that requires plans to 

demonstrate attainment “as expeditiously as practicable but no later than five years from the date 

such area was designated nonattainment. 

The U.S. EPA’s previous PM2.5 Implementation Rules and Guidance were challenged, partly 

because they were based on general implementation provisions under Subpart 1 of the CAA 

rather than the PM10 specific provision of Subpart 4 of the CAA. In January 2013, the U.S. 

Court of Appeals (Nat’l Res. Def. Council v. EPA, 706 F.3d 428 (D.C. Cir. 2013)) decided that 

the U.S. EPA misinterpreted the CAA relative to the statutory requirements for the 1997 PM2.5 

standards, erred in applying the provisions of Subpart 1 rather than Subpart 4, and needs to repromulgate the PM2.5 implementation rules with Subpart 4. On June 6, 2013, U.S. EPA 

withdrew the March 2012 Implementation Guidance for 2006 24-hour PM2.5 NAAQS.

CLEAN AIR ACT, TITLE 1, PART D, SUBPART 4

Title 1, Part D of the CAA outlines the plan requirements for nonattainment areas and is divided 

into six subparts. Subpart 1 provides general provisions for nonattainment areas; Subpart 2 

through 4 include, respectively, additional provisions for ozone, carbon monoxide and particulate 

matter nonattainment areas. Subpart 5 consists of additional provisions for areas designated 

nonattainment for sulfur oxide, nitrogen dioxide or lead. Finally, Subpart 6 lists a general savings 

clause.

Provisions in Subpart 4 are based on the classification of the nonattainment region as moderate

or serious. The South Coast Air Basin has been classified by U.S. EPA as moderate 

nonattainment for the 2006 24-hour PM2.5 NAAQS. For a moderate area, “the attainment date 

shall be, as expeditiously as practicable, but no later than the end of the sixth calendar year after 

the areas designation as nonattainment.” (CAA, Title 1, Part D, Subpart 4, Section 188(c)(1)) As 

discussed earlier, the South Coast Air Basin designation as non-attainment for the 2006 24-hour 

PM2.5 NAAQS (35 μg/m3) was effective December 14, 2009, thus providing for a latest 

attainment date of December 31, 2015. Subpart 4 provisions also allow for no more than 2 oneyear extensions of the attainment date for a “moderate” area as long as all SIP commitments are 

met and if the previous single year’s air quality shows attainment (Section 188 (d)). Finally, 

Subpart 4 Section 189(e) necessitates that control requirements applicable for major PM2.5 
Supplement to 24-hour PM2.5 SIP

4 February 2015

sources shall also apply to major sources of PM2.5 precursors unless U.S. EPA finds that major 

sources do not significantly contribute to nonattainment. PM2.5 has four major precursors, other 

than direct PM2.5 emissions, that contribute to the development of the ambient PM2.5: 

ammonia, nitrogen oxide (NOx), sulfur oxides (SOx), and volatile organic compounds (VOC). 

AIR QUALITY MONITORING DATA

Preliminary air quality monitoring data indicates that attainment of the 2006 24-hour PM2.5 

NAAQS (35 μg/m3) is not likely to be achieved by the end of 2014. It should be noted that U.S. 

EPA has proposed to find that the former 24-hour PM2.5 NAAQS (65 μg/m

3

) has been attained,

along with the previous annual PM2.5 NAAQS of 15 μg/m3(79, FR, 72999, Dec 9, 2014).

Attainment of the 2012 annual PM2.5 NAAQS of 12 μg/m3 will be addressed in the upcoming 

2016 AQMP. 

With regard to the air quality monitoring, only the Mira Loma location in Western Riverside 

County exceeds the 2006 24-hour PM2.5 NAAQS. Attainment of the PM2.5 standard is based 

on a “design value” equal to the 3-year average of the annual 98th percentile concentration with 

prescribed rounding conventions. In the case of the 2006 24-hour PM2.5 NAAQS, attainment is 

achieved if this design value is less than 35.4 μg/m3. Preliminary data through June 2014 shows 

a 98th percentile PM2.5 concentration in 2014 is 35 μg/m3. However, including the 98th

percentiles of the preceding two years as shown below, the design value at Mira Loma will likely 

exceed the standard. Note that the data for 2014 is preliminary, and that it does not include the 

November and December months of 2014 when exceedances have historically been observed.

2012: 35.8 μg/m3

2013: 37.5 μg/m3

2014: 35.0+ μg/m3

3-Year Average: > 36 μg/m3

Thus, according to this data, attainment of the 2006 24-hour PM2.5 NAAQS (35 μg/m3) will not 

be achieved by the end of 2014 as anticipated in the 2012 AQMP. As discussed below, the 

higher levels in 2013 and possibly 2014, which reverse a long term trend of improving PM2.5 

concentrations, were affected by extreme drought conditions in Southern California. 
Supplement to 24-hour PM2.5 SIP

5 February 2015

SUPPLEMENT TO THE 24-HOUR PM2.5 SIP

In close consultation with U.S. EPA and CARB, the SCAQMD is proposing to supplement the 

previous 24-hour PM2.5 SIP submittal to address Subpart 4 provisions and requirements with the 

following elements that are included in this Supplement:

 Demonstration of attainment of the 24-hour PM2.5 NAAQS by 2015;

 Discussion of the effects of the drought on the 2014 attainment date;

 Provide new transportation conformity budgets for 2015;

 Updated RACM/RACT analysis;

 Demonstration of compliance with CAA Subpart 4, Section 189(e) that applies to major 

source PM2.5 precursors, such as VOC and ammonia unless U.S. EPA finds these 

sources do not significantly contribute to nonattainment; and

 Updated list of control strategy commitments.

Upon adoption by the SCAQMD Governing Board, the Supplement will be submitted to CARB 

and subsequently to the U.S. EPA for inclusion into the SIP.

2015 ATTAINMENT DEMONSTRATION

The 2012 AQMP provided attainment projections for years 2014 and 2019 with the

implementation of all feasible control measures. To show attainment of the 2006 24-hour PM2.5 

NAAQS by 2015 as allowed under Subpart 4, the 2012 AQMP inventories and modeling results 

will be used in an interpolation analysis between the 2014 and 2019 projections. This 

demonstration can be found in Attachment A that also includes a discussion based on the 

emissions inventory and inter-pollutant weighting factors. 

EFFECTS OF THE DROUGHT

Attachment B includes a weight-of-evidence discussion on the lack of rainfall and drought 

conditions in the South Coast Air Basin for the past two years, and how that has impacted the 

PM2.5 ambient levels. Limited rain means there is less crusting and wetting of soil and road 

surfaces. Thus, more road dust and fugitive dust emissions are generated. A reduced frequency 

of storms translates to fewer days of enhanced pollution dispersion. Without such dispersion, 

there is no deep mixing of the atmosphere, particulate matter captured by raindrops or wind to 

transport the pollution away from the region. Finally, Attachment B will include a discussion of 

the impact of a continued drought on the 2015 attainment demonstration. Given the weather 

conditions and ambient data in 2013 and 2014, the earliest practicable attainment date for the 24-

hour PM2.5 NAAQS is 2015.
Supplement to 24-hour PM2.5 SIP

6 February 2015

PATHS FORWARD

Despite the attainment demonstration mentioned above, there remains considerable uncertainty 

in the PM2.5 monitoring results for 2014 and the meteorological conditions and frequency of

rainfall that will occur in 2015. In order to demonstrate attainment the 98th percentile of the 

2015 24-hr PM2.5 readings at Mira Loma has to be significantly below the standard of 35.4 

ug/m3 to compensate for high exceedances caused by the drought in 2013 and 2014, achieving a 

3-year average design value at or below the standard. Although additional emissions reductions 

are expected in 2015, attainment of the standard, given the variability of weather conditions, 

remains far from certain. Acknowledging this uncertainty, there are several potential outcomes 

and pathways for the Basin’s attainment status under the Clean Air Act depending on the actual 

certified air quality monitoring results for 2014 and 2015.

 24-hour PM2.5 data at Mira Loma for 2014 and 2015 is clean enough to attain the 

standard based on a three-year (2013-2015) average design value. The Basin could 

then be re-designated as attainment for this PM2.5 standard

 The three-year average design value at Mira Loma does not show attainment in 2015, 

but the 98th percentile of the 24-hour PM2.5 data at Mira Loma for the single year 2015 

is below 35.4 μg/m3. Under CAA Subpart 4 provisions, if this air quality condition is 

met, and all PM2.5 SIP commitments have been satisfied, then the Basin is eligible for 

a one-year attainment date extension to 2016. A second one-year extension to 2017, if 

the same conditions are met in 2016, is also possible.

 The three-year average design value at Mira Loma does not show attainment in 2015 

and the 98th percentile of the 24-hour PM2.5 data at Mira Loma for the single year 2015 

is above 35.4 μg/m3. Under Subpart 4 of the CAA, upon U.S. EPA’s determination that 

the Basin failed to attain the standard by the attainment date, the Basin would be 

automatically reclassified from a “moderate” nonattainment area to a “serious” nonattainment area. The new attainment deadline would be 2019, and more stringent 

“serious” area requirements would apply, including requirements to implement Best 

Available Control Measures (BACM) and a lower major source threshold (70 tons per 

year vs. the current 100 tons per year). A full analysis for implementation of these 

requirements and other control measures to ensure attainment as expeditiously as 

practicable would be included in the 2016 AQMP, which is also addressing the annual 

2012 PM2.5 standard.
Supplement to 24-hour PM2.5 SIP

7 February 2015

2015 TRANSPORTATION CONFORMITY BUDGETS

Attachment C includes new transportation conformity budgets based on the interpolated 2015 

vehicle miles traveled (VMT) used for the attainment demonstration.

RACM/RACT ANALYSIS

A RACM demonstration, including a RACT analysis, was submitted to U.S. EPA as component 

of 2012 AQMP. Updates to the RACM/RACT analysis, which addresses direct PM2.5 and 

precursor emissions, can be found in Attachment D.

CAA SUBPART 4, SECTION 189(e) AND OTHER PRECURSOR REQUIREMENTS

CAA Subpart 4, Section 189(e) addresses control requirements for major stationary sources of

PM2.5 precursors, such as VOC and ammonia. The sections states, “the control requirements 

applicable under plans in effect under this part for major stationary sources of PM–10 shall also 

apply to major stationary sources of PM–10 precursors, except where the Administrator 

determines that such sources do not contribute significantly to PM–10 levels which exceed the 

standard in the area.” SCAQMD staff’s analysis (see Attachment E) shows that VOC and 

ammonia from major sources (100 tons per year or greater) do “not contribute significantly” to

overall emissions and thus ambient PM2.5 levels. Furthermore, both VOC and ammonia are 

subject to requirements for Best Available Control Technology (BACT) under existing New 

Source Review at a zero threshold, so those emission will still be minimized. VOC emissions 

are also required to be offset when a new or modified source will emit four tons per year or more 

of VOC, well below the level at which the PM2.5 requirement would require offsets. So, the 

only practical difference between the existing control program for New Source Review and a 

program that expressly applies to VOC and ammonia as PM2.5 precursors is that any new or 

modified source of 100 tons per year or more of ammonia will not need offsets. As explained 

Attachment E, it is extremely unlikely that there would be a new stationary source of 100 tons 

per year of ammonia anywhere in the Basin. Moreover, the SCAQMD has adopted numerous 

rules limiting VOCs, continually seeking all feasible reductions, as part of the stringent ozone 

control program. Thus, the SCAQMD believes the requirements of CAA Subpart 4, Section 

189(e) and other precursor requirements are satisfied and thus request that the Administrator of 

U.S. EPA makes this determination.

CONTROL STRATEGY COMMITMENTS

Attachment F provides an updated list of control strategy commitments originally proposed in 

the 2012 AQMP in Chapter 4 (Control Strategy and Implementation).
A T T A C H M E N T A

A T T A I N M E N T D E M O N S T R A T I O N O F T H E 2 4 – H O U R 

P M 2 . 5 N A T I O N A L A M B I E N T A I R Q U A L I T Y 

S T A N D A R D F O R 2 0 1 5 
Attachment A: Attainment Demonstration of 24-hr PM2.5 NAAQS for 2015

A-1 February 2015

BACKGROUND

The 2012 AQMP provided a comprehensive attainment demonstration for the 2006 24-hour

PM2.5 NAAQS (35 μg/m3) in 2014 for the South Coast Air Basin (Basin). The analysis which is 

presented in Chapter 5 of the AQMP main document and Appendix V provides a detailed 

discussion of the modeling analysis including modeling platforms (both meteorological and 

dispersion), chemical modules, model parameterization, emissions, background concentrations, 

base year performance and future year baseline and controlled PM2.5 projections. The 

attainment demonstration was anchored using the 2008 base year AQMP inventory and future 

year projections based on regional growth factors provided by the Southern California 

Association of Governments. The analysis followed U.S. EPA modeling guidance in simulating 

the speciated 98th percentile 24-hour PM2.5 levels for the 2014 baseline and controlled emissions 

scenarios as well as the 2019, 2023 and 2030 controlled scenarios. The NWS WRF 

meteorological model and the CMAQ dispersion model coupled with SAPRC99 chemistry were 

the primary modeling tools employed in the analyses. Boundary conditions were developed from 

GEOS-Chem global simulation model output. Simulations were conducted for gridded domain 

encompassing the majority of Southern California, northern Baja Mexico and the eastern Pacific 

Ocean. 

The analysis demonstrated attainment of the 24-hour standard in 2014 for the controlled 

emissions based on the application of simulation determined, particulate species specific, relative 

reduction factors (RRF) applied to a 5-year weighted speciated 2008 design value. The 

demonstration showed attainment in 2014 at the Mira Loma Basin design site for the controlled 

emissions with a predicted design concentration of 34.3 μg/m3. Subsequent simulations for 

controlled emissions indicated that the standard would be met with a 2019 design value of 35.4 

μg/m3decreasing to 33.7 μg/m3 in 2023 and 33.4 μg/m3by 2030. (The threshold design value 

for demonstrating attainment to the standard for model simulations is set at 35.4 μg/m3based on 

established rounding conventions). The demonstration provided future year controlled 

emissions projections of 24-hr PM2.5 design values for six additional monitoring locations 

including Rubidoux, the former Basin design site, Fontana – an area heavily impacted by local 

industry including warehouse distribution centers, Central Los Angeles, South Long Beach and 

North Long Beach – areas impacted by goods movement related emissions sources, and 

Anaheim representing urban residential impacts. Finally the demonstration also included an 

unmonitored area analysis to confirm that all PM2.5 impact areas were being fully assessed in 

the analysis.

DROUGHT IMPACT ON AIR QUALITY

The west coast of the U.S. has experienced a severe drought for the past several years with 2013 

annual rainfall total measured at Downtown Los Angeles of 3.6 inches, far below the 14.9 inch 

long term average. Rainfall events of 0.01 inches of rain or more were 25 percent lower than the 

average of 28 days typically occurring during the 1st and 4th quarters of the year. Under the 
Attachment A: Attainment Demonstration of 24-hr PM2.5 NAAQS for 2015

A-2 February 2015

drought conditions, Mira Loma 24-hr PM2.5 98th percentile concentrations experienced a 

reversal in the long-term trend of declining concentrations rising from a 2012 value of 35.1 

μg/m3to 37.5 μg/m3 in 2013. Based on a conservative analysis of the impact of rain fall events 

on the 98th percentile concentration, the drought accounted for roughly 1.6 μg/m3additional 

mass to the observed 98th percentile concentration. (A discussion of the rain event-concentration 

impact is provided in Attachment B). It is anticipated that the 2014 Basin 24-hr PM2.5 design 

value (measured at Mira Loma) based on the 2012-2014 3-year average of the 98th percentile 

concentration will exceed 35.4 μg/m3due to the observed continuation of the drought.

ANALYSIS UPDATE

An update of the 2012 24-hour PM2.5 attainment demonstration has been conducted to show 

attainment of the NAAQS for the year 2015, based on a 2015 controlled emissions inventory. 

The analysis uses the 2014 and 2019 projected design values using the controlled emissions to 

calculate the 2015 expected design. The 2015 design value was calculated using linear 

interpolation by component species between the two milestone years. In addition, the analysis 

includes an update to the unmonitored area attainment demonstration.

To corroborate the interpolation based attainment demonstration, an analysis is provided to 

assess the impact to the 2014 design value resulting from changes in the projected controlled 

emissions inventory from 2014 to 2015 using emissions (tons per day) to species projected 

PM2.5 concentrations ratios. 

2015 24-HR PM2.5 ATTAINMENT DEMONSTRATION

Table A-1 summarizes the site specific 2015 24-Hr PM2.5 attainment demonstration. The 

maximum concentration for the Basin is projected to continue to occur at the Mira Loma 

monitoring site with an expected design value of 34.5 μg/m

3

. Figure A-1 illustrates the 2015 

predicted design values by component species. The largest contribution to the 2015 design value 

is nitrate followed by organic carbon. Table A-2 provides the corresponding 2014 and 2019

projected design values for the seven stations analyzed in the interpolation analysis.

Appendix V of the 2012 AQMP provided a comprehensive unmonitored area analysis that 

demonstrates that all grid cells covered by the regional modeling simulation were predicted to 

have 2014 design concentrations meeting the 24-Hr PM2.5 35 μg/m3standard. The projected 

average change in design concentration between 2014 and 2015 is estimated to be a 0.2 μg/m3

increase in PM2.5 but this will not result in a change in the attainment demonstration in 2015. 

A corresponding 0.2 μg/m3increase was added to the concentration in cell (89,58), the cell with 

the peak unmonitored area design concentration. The resulting design concentration of 31.4 

μg/m3for 2015 meets the unmonitored area attainment test. TableA-3 summarizes the projected 

change in predicted particulate component species for the seven sites. 
Attachment A: Attainment Demonstration of 24-hr PM2.5 NAAQS for 2015

A-3 February 2015

TABLE A-1

2015 24-Hr PM2.5 Attainment Demonstration

Station Predicted Mass

(μg/m3)

Anaheim 27.0

S. Long Beach 25.0

Fontana 33.1

N. Long Beach 28.7

Los Angeles 31.8

Mira Loma 34.5

Rubidoux 32.5

FIGURE A-1

2015 24-Hr PM2.5 Predicted Component Species Design Concentrations

(The red band at 3g micrograms per cubic meter depicts the Federal Standard)

KEY:

EC = elemental carbon

OC = organic carbon

SO4 = sulfate

NO3 = nitrate

NH4= ammonium

Others = crustal metals

0

5

10

15

20

25

30

35

40

μg/m3

Blank

Water

Others

EC

OC

SO4

NO3

NH4
Attachment A: Attainment Demonstration of 24-hr PM2.5 NAAQS for 2015

A-4 February 2015

TABLE A-2

Component Interpolated 24-Hour Average PM2.5 2015 Attainment Demonstration

YEAR NH4 NO3 SO4 OC EC Others Water Blank Mass

Anaheim

2014 2.9 7.5 2.2 6.6 2.8 3.5 1.5 0.5 27.5

2015 3.02 7.78 2.28 6.62 2.86 3.46 1.54 0.5 28.0

2019 3.5 8.9 2.6 6.7 3.1 3.3 1.7 0.5 30.2

S. Long Beach

2014 3 6.9 2.5 5.6 3.1 2 1.4 0.5 24.8

2015 3 6.88 2.52 5.76 3.1 2.02 1.42 0.5 25.0

2019 3 6.8 2.6 6.4 3.1 2.1 1.5 0.5 25.9

Fontana

2014 4.7 11.8 1.9 5.3 3.3 3.5 2.1 0.5 32.9

2015 4.64 11.66 1.92 5.64 3.32 3.5 2.1 0.5 33.1

2019 4.4 11.1 2 7 3.4 3.5 2.1 0.5 33.9

N. Long Beach

2014 3.8 8.2 3.4 5.8 2.8 2.1 1.7 0.5 28.3

2015 3.82 8.28 3.4 6.04 2.82 2.12 1.72 0.5 28.7

2019 3.9 8.6 3.4 7 2.9 2.2 1.8 0.5 30.3

Los Angeles

2014 4.6 10.5 3.3 5.6 2.7 2.6 2 0.5 31.8

2015 4.46 10.2 3.36 5.98 2.62 2.72 1.98 0.5 31.8

2019 3.9 9 3.6 7.5 2.3 3.2 1.9 0.5 31.9

Mira Loma

2014 4.9 12.8 2 5.6 2.9 3.2 2.3 0.5 34.3

2015 4.86 12.72 2.02 5.84 2.96 3.28 2.26 0.5 34.5

2019 4.7 12.4 2.1 6.8 3.2 3.6 2.1 0.5 35.4

Rubidoux

2014 4.7 13 2 4.7 2.5 2.8 2.4 0.5 32.5

2015 4.62 12.52 2.1 5.02 2.56 2.98 2.32 0.5 32.5

2019 4.3 10.6 2.5 6.3 2.8 3.7 2 0.5 32.5
Attachment A: Attainment Demonstration of 24-hr PM2.5 NAAQS for 2015

A-5 February 2015

TABLE A-3

Average Interpolated Change in Component Species Concentrations from 2014 to 2015

(μg/m3)

Station NH4 NO3 SO4 OC EC Others Water Blank Mass

Anaheim 0.1 0.3 0.1 0.0 0.1 0.0 0.0 0.0 0.5

S. Long Beach 0.0 0.0 0.0 0.2 0.0 0.0 0.0 0.0 0.2

Fontana -0.1 -0.1 0.0 0.3 0.0 0.0 0.0 0.0 0.2

N. Long Beach 0.0 0.1 0.0 0.2 0.0 0.0 0.0 0.0 0.4

Los Angeles -0.1 -0.3 0.1 0.4 -0.1 0.1 0.0 0.0 0.0

Mira Loma 0.0 -0.1 0.0 0.2 0.1 0.1 0.0 0.0 0.2

Rubidoux -0.1 -0.5 0.1 0.3 0.1 0.2 -0.1 0.0 0.0

Average 0.0 -0.1 0.0 0.2 0.0 0.1 0.0 0.0 0.2

EMISSIONS INVENTORY APPROACH

Table A-4 presents the 2015 interpolated Basin total emissions inventory and the change from 

the 2014 projection. Both VOC and NOX emissions are projected to be lower by 7.9 and 17.8 

TPD respectively in 2015. Little change was projected in SOx emissions and directly emitted 

particulate emissions are estimated to grow at a nominal rate of 0.1 tons per day. The 2012 

AQMP provided a set of estimated emissions (TPD) to particulate formation potential (μg/m3) 

ratios for VOC, NOx, SOx, and PM2.5 to secondary organic carbon, nitrate, sulfate and the 

combination of primary organic compound, elemental carbon and others. The ratios can provide 

an estimate of the relative contribution of emissions to particulate formation and be used to 

roughly estimate the magnitude of change in particulate expected from changes in the emissions 

inventory. Please note that the ratios were calculated specifically for a 2014 inventory; they are 

used here to estimate the magnitude of the expected net change in the 2015 PM2.5 particulate 

concentrations from 2014. These estimates are compared to the average change in component 

species concentrations (listed in Table A-2) where nitrates and sulfates are calculated to 

incorporate ammonium and bonded water. 

As shown in Table A-4, the projected change in baseline emissions from 2014 to 2015 is 

estimated to result in 0.3 μg/m3reduction in regional nitrate and a small increase in primary 

PM2.5. The average projected changes in the 2015 attainment demonstration from the 

interpolation analysis show a comparable reduction in nitrate, a nominal increase (0.1 μg/m3) in 

sulfate and a larger 0.2 μg/m3 increase in primary PM2.5. While the estimates do not exactly 

match, the magnitude of the change and the direction (increase or decrease) for the key 

components is aligned. This indicates that the interpolated PM2.5 attainment demonstration is 

consistent with the projected change in emissions.
Attachment A: Attainment Demonstration of 24-hr PM2.5 NAAQS for 2015

A-6 February 2015

TABLE A-4

Average Interpolated Change in Component Species Concentrations from 2014 to 2015 

(μg/m3)

VOC

(TPD)

NOX

(TPD)

SOX

(TPD)

PM2.5

(TPD)

2014 Controlled Emissions 451.1 506.0 18.4 69.9

2015 Interpolated Controlled 

Emissions 443.2 488.2 18.4 70.0

TPD Change: 2014-2015 -7.9 -17.8 0 +0.1

SECONDARY

ORGANIC 

CARBON

NITRATE SULFATE

PRIMARY 

ORGANIC 

CARBON + 

ELEMENTAL 

CARBON + 

OTHERS

Per Ton Conversion Factors: 

PM2.5 (μg/m3) /TPD 0.004 0.014 0.111 0.2132

2014-2015 Emissions Inventory 

Projected Change in PM2.5 

(μg/m3) 0.0 -0.3 0 0.02

Average Simulated Change in 

PM2.5 Concentration (μg/m3) 

2014-2105 0.0 -0.1 0.1 0.2

SUMMARY

The revised analysis demonstrates attainment of the 24-hour PM2.5 standard in the Basin, 

including unmonitored areas, by 2015 using interpolation techniques supported by projected 

emissions. However, there remains considerable uncertainty in the meteorological conditions 

and frequency of rainfall that will occur in 2015. In order to demonstrate attainment the 98th

percentile of the 2015 24-hr PM2.5 readings at Mira Loma has to be significantly below the 

standard of 35.4 ug/m3 to compensate for high exceedances caused by the drought in 2013 and 

2014, achieving a 3-year average design value at or below the standard. Although additional 

emissions reductions are expected in 2015, attainment of the standard, given the variability of 

weather conditions, remains far from certain.

REFERENCES

1. South Coast Air Quality Management District, Final 2012 Air Quality Management Plan, 

Diamond Bar, CA., February 2013.
Attachment A: Attainment Demonstration of 24-hr PM2.5 NAAQS for 2015

A-7 February 2015

2. South Coast Air Quality Management District, Final 2012 Air Quality Management Plan, 

Appendix V, Modeling Attainment Demonstrations, Diamond Bar, CA., February 2013.
A T T A C H M E N T B

E F F E C T S O F T H E D R O U G H T 
Attachment B: Effects of the Drought

B-1 February 2015

BACKGROUND

The 2014 attainment demonstration was based on simulated RRFs applied to a weighted 2008 design 

value. The 5-year weighted PM2.5 design value incorporated 98th percentile concentrations from 

2006 through 2010. The five year period used for the design calculation covered a meteorological 

period, when assessed for the frequency of rainfall events and precipitation accumulations, was 

essentially average compared to the long term (50+ year) statistics. As a consequence, the 2014 

projected 24-hour PM2.5 design value for Mira Loma assumed a similar window of average 

precipitation events and rainfall totals with the concurrent natural pollution dispersion potential 

associated with the unstable weather. 

Unfortunately, the west coast of the U.S. has experienced a severe drought for the past several years 

with 2013 annual rainfall total measured at Downtown Los Angeles of 3.6 inches, far below the 14.9 

inch long term average. Rainfall events of 0.01 inches of rain or more were 25 percent lower than the 

average of 28 days typically occurring during the 1st and 4th quarters of the year. Under the drought 

conditions, Mira Loma 24-hr PM2.5 98th percentile concentrations experienced a reversal in the longterm trend of declining concentrations rising from a 2012 value of 35.1 μg/m3

to 37.5 μg/m3 in 2013. 

Based on a conservative analysis of the impact of rain fall events on the 98th percentile concentration, 

the drought accounted for roughly 1.6 μg/m3to the observed 98thpercentile concentration. (A 

discussion of the rain event-concentration impact is provided in the weight of evidence discussion).

Through October, the drought has continued and only 8 rain days have been observed at Downtown 

Los Angeles in 2014. More specifically, no rain fell in January with only two days of minor 

precipitation in February before the 26th. Note that historically the majority of exceedances of the 

standard occur between November and February. Concurrently, the preliminary un-validated 

observed 98th percentile concentration at Mira Loma was measured at 35 μg/m

3

through June. Given

that the 4

th quarter has the potential for higher PM2.5 concentrations, it is anticipated that the 2014 

Basin 24-hr PM2.5 design value (measured at Mira Loma) based on the 2012-2014 3-year average of 

the 98th percentile concentration will exceed 35.4 μg/m3. 

The focus of this discussion is to address the impact of the drought on the 24-hour PM2.5 attainment 

by first developing a methodology to correct for variations in rainfall frequency then applying that 

methodology to the trend of ambient PM2.5 to determine the likelihood for future compliance. 

ACCOUNTING FOR SEASONAL VARIATIONS IN RAINFALL FREQUENCY

As described above, the West Coast of the U.S. has been impacted by a multiple year drought that has 

reduced the frequency of rain events and increased the likelihood for atmospheric stagnation. A 

question has arisen as to what would be the impact to the 2015 attainment demonstration if the 

drought continues beyond 2014. To assess this potential situation, an algorithm was generated to 

adjust the predicted annual PM2.5 98th percentile concentration based on the deviation from the 

average expected rain frequency. The form of the adjustment was based on the rainfall correction 

applied to fugitive dust in U.S. EPA AP-42 and is presented through the following equation:
Attachment B: Effects of the Drought

B-2 February 2015

(Q-1 Exp + Q-4 Exp) – (Q-1 Obs + Q-4 Obs)

 Rain Frequency Factor (RFF) = 1 + 

182 - (Q-1 Obs + Q-4 Obs)

Where: Q-1 Exp = Number of 1st quarter expected rain events ≥ 0.01 “ rainfall

Q-4 Exp = Number of 4th quarter expected rain events ≥ 0.01 “ rainfall

Q-1 Obs = Number of 1st quarter observed rain events ≥ 0.01 “ rainfall

Q-4 Obs = Number of 4th quarter observed rain events ≥ 0.01 “ rainfall

The fit of the frequency of rainfall events in the 1st and 4th quarters to the quarterly total rainfall is 

depicted in Figures B-1a and B-1b. The greater variation in rainfall events occurs in the 1st quarter 

while the 4th quarter clusters around the number of events below 10. Overall, averages of 28 rain 

events are expected to occur between the two quarters.

FIGURE B-1a

Power Fit of 1st Quarter Rain Events (1960-2013)

FIGURE B-1b

Power Fit of 4th Quarter Rain Events (1960-2013)

y = 0.0809x1.5957

R2 = 0.8758

0

5

10

15

20

25

30

0 10 20 30 40

Inches of Rain 

Days of Rain

1

st

-Quarter y = 0.1166x1.4466

R2 = 0.6568

0

5

10

15

20

25

30

0 10 20 30

Inches of Rain

Days of Rain

4

th

-Quarter
Attachment B: Effects of the Drought

B-3 February 2015

Figure B-2 depicts the trend of the drought adjustment factor calculated as the inverse of the rain 

frequency factor. The red circle focuses on 2006 - 2010, the period used to develop the 2008 

weighted 24-hour PM2.5 design value for Mira Loma used in the attainment demonstration. When 

the same weighting scheme is applied to the adjustment factors, the average valued 0.999; thereby 

indicating the 2008 Mira Loma design value was not impacted by either drought or excessively 

frequent rain events. The adjustment factor was applied to the 2006 through 2013 Mira Loma 24-

hour 98th percentile PM2.5 to normalize the annual concentration for year–to-year variations in 

drought potential. Figure B-3 presents the trend of the rain event normalized 98th percentile 

concentrations for Mira Loma. The trend was extended to both 2014 and 2015 to provide an estimate 

of the data for a normal rain event scenario (28 days combined for the 1st and 4th quarters). 

Table B-1 provides the observed rain day summary for the Basin as measured at Downtown Los 

Angeles. Rain day totals for 2014 include the observed total for Q-1 and the long-term average 

number of days for Q-4. For this analysis, 2015 rain day totals are assumed equal to 2014 rain day 

totals. The rain frequency factor (RFF) is for each year and the adjustment factor (1/RFF) to estimate 

rainfall which assumes that the year experiences the long term average numbers of rain days are also 

provided. 

FIGURE B-2

Trend of Annual Drought Adjustment Factor (1/RFF)

0.6

0.7

0.8

0.9

1

1.1

1.2

1.3

1.4

1998 2003 2008 2013

Adjustment Factor
Attachment B: Effects of the Drought

B-4 February 2015

FIGURE B-3

Power Law Fit of Mira Loma PM2.5 Adjusted for Normal Rainfall

TABLE B-1

Trend Estimated Impact of the Drought on Basin 24-Hr PM2.5 Attainment

2006 2007 2008 2009 2010 2011 2012 2013 2014* 2015**

Annual Rainfall

11.61 5.66 14.43 9.39 23.09 12.26 8.15 3.6 5.16 5.16

Q-1 Rain Days

19 10 19 12 18 17 11 13 8 8

Q-4 Rain Days

8 9 12 9 26 10 20 8 10 10

Q-1 & Q-4 Rain Days

27 19 31 21 44 27 31 21 18 18

Rain Freq Factor (RFF)

1.006 1.055 0.98 1.043 0.884 1.006 0.98 1.043 1.061 1.061

Adjustment Factor (1/RFF) To Estimate PM2.5 for Average Weather Year Rainfall

0.994 0.948 1.02 0.958 1.131 0.994 1.02 0.958 0.943 0.943

* 2014 Q-4 rain events assumed average (10)

** 2015 Drought assumed as severe as 2014

y = 167.08x-0.615

R2 = 0.8465

0

10

20

30

40

50

60

5 6 7 8 9 10 11 12 13 14

Annual 98th Percentile μg/m3

Year (Beginning 2005)
Attachment B: Effects of the Drought

B-5 February 2015

ESTIMATING THE IMPACT OF THE DROUGHT ON THE PM2.5 TREND

Table B-2 first presents the 24-hr PM2.5 data for the Mira Loma design site including the observed 

98th percentile concentration from 2006 through 2013 and the three year average design value for 

2008 through 2013. Table B-2 then outlines the steps to estimate the drought impact to the observed 

Mira Loma annual 98th percentile concentration and the methodology to estimate the impact to both 

2014 and 2015. 

Step-1 adjusts the observed 98th percentile Mira Loma data to estimate the trend for average rain 

events. Step-2 and Step-3 use the power law equation (shown in Figure A-4) to estimate the 98th

percentile concentration at Mira Loma for 2006 through 2015 based on the trend and the assumption 

of average rain event occurrences. The trend projected concentrations for 2014 and 2015 are 

projected to be 32.97 and 31.60 μg/m3for average rain years. Step-5 applies the RFF to the 2014 and 

2015 normalized 98th percentile PM2.5 estimated concentrations to address the drought conditions. 

Step-6 adds the projected 2014 drought impacted 98th percentile concentration to the observed values 

for 2006 through 2013. Step-7 presents the revised design values which now incorporate the 

estimated impact of the 2014 drought. As estimated, the 2014 design value is expected to fail to meet 

attainment reflecting the severity of the 2013 and 2014 drought conditions. Steps-8 and-9 repeat 

Steps-6 and-7 but with the addition of the 2015 power law estimated 2015 98th percentile to estimate 

the potential for attainment to the NAAQS if the weather returns to average conditions. In this 

scenario, the projected 2015 98th percentile concentration and the 2015 design value will meet the 

NAAQS. Steps-10 and -11 repeat steps-8 and -9 for the 2015 assumption of continued drought. As 

calculated, the projected 2015 98th percentile concentration and the 2015 design value will still meet 

the NAAQS under continued drought conditions.

SUMMARY

The preceding analysis projects attainment of the 24-hour PM2.5 standard by 2015, considering the 

effects of recent drought conditions. However, there remains considerable uncertainty in the PM2.5 

monitoring results for 2014 and the meteorological conditions and frequency of rainfall that will 

occur in 2015. In order to demonstrate attainment the 98th percentile of the 2015 24-hr PM2.5 

readings at Mira Loma has to be significantly below the standard of 35.4 ug/m3 to compensate for 

high exceedances caused by the drought in 2013 and 2014, achieving a 3-year average design value at 

or below the standard. Although additional emissions reductions are expected in 2015, attainment of 

the standard, given the variability of weather conditions, remains far from certain.
Attachment B: Effects of the Drought

B-6 February 2015

TABLE B-2

Trend Estimated Impact of the Drought on Basin 24-Hr PM2.5 Attainment

2006 2007 2008 2009 2010 2011 2012 2013 2014* 2015**

Mira Loma Observed 98th Percentile PM2.5

52.5 60.1 47.14 40.62 36.17 36.7 35.83 37.5

Mira Loma PM2.5 Design***

53.2 49.3 41.3 37.8 36.2 36.7

Step-1: Mira Loma Adjusted for Average Weather Year Rainfall

52.16 56.96 48.1 38.93 40.91 36.46 36.56 35.94

Step-2: Mira Loma Design Adjusted for Average Weather Year Rainfall

52.4 48 42.6 38.8 38 36.3

Step-3: Power Law Fit of Mira Loma Adjusted for Average Weather Year Rainfall

55.51 50.49 46.51 43.26 40.54 38.24 36.24 34.5

Step-4: Mira Loma Trend Projected 2014 & 2015 98th Percentile PM2.5 With Average Rainfall

32.97 31.60

Step-5: Mira Loma Trend Projected 2014 & 2015 98th Percentile PM2.5 Adjusted for Drought

34.98 33.53

Step-6: Mira Loma 98th Percentile with Trend Projected 2014 98th Percentile PM2.5 Adjusted for Drought

52.5 60.1 47.14 40.62 36.17 36.7 35.83 37.5 34.98

Step-7: Mira Loma Design with Trend Projected 2014 98th Percentile PM2.5 Adjusted for Drought

53.2 49.3 41.3 37.8 36.2 36.7 36.1

Step -8: Mira Loma 98th Percentile with Trend Projected 2014 98th Percentile PM2.5 Adjusted for Drought & 2015 Average

52.5 60.1 47.14 40.62 36.17 36.7 35.83 37.5 34.98 31.60

Step-9: Mira Loma Design with Trend Projected 2014 98th Percentile PM2.5 Adjusted for Drought & Average 2015

53.2 49.3 41.3 37.8 36.2 36.7 36.1 34.7

Step-10: Mira Loma 98th Percentile with Trend Projected 2014 & 2015 98th Percentile PM2.5 Adjusted for Drought

52.5 60.1 47.14 40.62 36.17 36.7 35.83 37.5 34.98 33.53

Step-11: Mira Loma Design with Trend Projected 2014 & 2015 98th Percentile PM2.5 Adjusted for Drought

53.2 49.3 41.3 37.8 36.2 36.7 36.1 35.3

* 2014 Q-4 rain events assumed average (10)

** 2015 Drought assumed as severe as 2014

*** Design values are based on 3-year average and 98th percentile concentration. For example, 53.2 μg/m3in 2008 is derived 

from the average of 2006-2008 data (52.5 + 60.1 + 47.14)/3 = 53.2 μg/m3

REFERENCES

1. South Coast Air Quality Management District, Final 2012 Air Quality Management Plan, 

Diamond Bar, CA., February 2013.
Attachment B: Effects of the Drought

B-7 February 2015

2. South Coast Air Quality Management District, Final 2012 Air Quality Management Plan, 

Appendix V, Modeling Attainment Demonstrations, Diamond Bar, CA., February 2013.

3. U.S. EPA, AP-42, Section 13.2.1, Paved Roads,

http://www.epa.gov/ttn/chief/ap42/ch13/final/c13s0201.pdf.
A T T A C H M E N T C

N E W T R A N S P O R T A T I O N C O N F O R M I T Y B U D G E T S

F O R 2 0 1 5
Attachment C: New Transportation Conformity Budget for 2015

C-1 February 2015

BACKGROUND

U.S. EPA's transportation conformity rule, found in 40 CFR parts 51 and 93, details the 

requirements for establishing motor vehicle emissions budgets in SIPs for the purpose of 

ensuring the conformity of transportation plans and programs with the SIP attainment 

demonstration. The on-road motor vehicle emissions budgets act as a "ceiling" for future onroad mobile source emissions. Exceedances of the budget indicate an inconsistency with the 

SIP, and could lead to a conformity “lapse” and its related consequences if not corrected before 

the next conformity deadline (e.g., during a lapse, certain categories of transportation projects 

cannot proceed). As required by the CAA, a comparison of regional on-road mobile source 

emissions to these budgets will occur during the periodic updates of regional transportation plans 

and programs.

The on-road motor vehicle emissions estimates for the Final 2012 AQMP were analyzed using 

CARB’s EMFAC2011 emission factors for the transportation activity data provided by Southern 

California Association of Governments (SCAG) from their adopted 2012 Regional 

Transportation Plan (2012 RTP). This update which is in response to the Subpart-4 

requirements replaces the on-road motor vehicle budgets for 2014 with those for 2015 the 

revised attainment date. The PM2.5 emissions budgets for PM2.5, and the PM2.5 precursors, 

VOC and NOx, are derived from the annual average inventory. 

This approach is consistent with U.S. EPA's transportation conformity rule, which provides that 

if emissions budgets rely on new control measures, these measures must be specified in the SIP 

and the emissions reductions from each control measure must be quantified and supported by 

agency commitments for adoption and implementation schedules. Moreover, the rule provides 

that conformity analyses by transportation agencies may not take credit for measures which have 

not been implemented unless the measures are "projects, programs, or activities" in the SIP 

supported by written implementation commitments by the responsible agencies (40 CFR 

93.122(a)(3)). The emissions budgets for PM2.5 are provided for the 2015 attainment year. 

However, since transportation analyses are needed beyond the attainment dates, the carrying 

capacities for the PM2.5 attainment demonstration also serve as the budgets for future years. For 

transportation conformity analysis, a trading mechanism can be established based on the PM2.5 

forming potential developed through the modeling analysis for the emission budgets for various 

pollutants in SCAB. 

2015 VMT AND MOTOR VEHICLE BUDGETS

As previously stated, the 2014 motor vehicle emissions budgets were based on 2012 RTP Final 

annual average VMT data provided by SCAG. At that time, SCAG provided VMT projections 

for several milestone years including 2019. Attachment D of Appendix III of the 2012 AQMP 
Attachment C: New Transportation Conformity Budget for 2015

C-2 February 2015

lists the VMT distributions and on-road emissions by vehicle category generated by EMFAC11 

using the 2012 RTP VMT for the two years. 

The 2015 VMT distribution was interpolated from the 2012 RTP analysis years 2014 and 2019 

profiles provided by SCAG. The 2015 VMT derived from the interpolation was input to 

EMFAC11 to generate the 2015 on-road motor vehicle emissions budgets listed in Table C-1.

TABLE C-1

2015 Motor Vehicle Emissions Budgets: PM2.5

(Annual Average - Tons Per Day)*

VOC NOx PM2.5

Baseline EMFAC 2011 114.26 265.94 11.74

RFG -4.27 -- --

SMOG Check -4.75 -2.60 --

 PM2.5: Re-entrained Road Dust (paved) -- -- 7.29

 PM2.5 Re-entrained Road Dust (unpaved) -- -- 0.58

 Road Construction Dust -- -- 0.22

2015 Mobile Source Emission Budget** 106 264 20

*Rounded up to the nearest whole number

**2015 budget is applicable to all future years beyond 2015.

In the Final 2012 AQMP the approximate weighting ratios of the precursor emissions for 24-

hour PM2.5 formation in equivalent tons per day of NOx are: VOC: 0.3 (reducing one ton of 

VOC is equivalent to reducing 0.3 ton of NOx), NOx: 1.0, and PM2.5: 14.8 (i.e., reducing one 

ton of PM2.5 is equivalent to reducing 14.8 tons of NOx). This mechanism allows emissions 

below the budget for one pollutant to be used to supplement another pollutant exceeding the 

budget based on the ratios established herein. Clear documentation of the calculations used in 

the trading should be included in the conformity analysis. This trading approach is consistent 

with what U.S. EPA approved in 2011, The Revisions to the 2007 PM2.5 SIP, where the 

precursor substitution methodology was established.

The basic trading ratios are defined by the 24-hour PM2.5 regional modeling attainment 

demonstration. Briefly, NOx emissions reductions are scaled to the reduction of Basin 

ammonium nitrate (including water bonding). Similarly, reductions of VOC are scaled to 

changes in the organic carbon species while reductions in directly emitted particulates are scaled 
Attachment C: New Transportation Conformity Budget for 2015

C-3 February 2015

to the projected changes in the elemental carbon and “others” portions of the PM2.5 mass. Table

C-2 summarizes the trading equivalencies in TPD.

TABLE C-2

Trading Equivalencies for PM2.5Motor Vehicle Emissions Budgets

ONE TON OF IS EQUIVALENT IN TERMS OF PM2.5 

FORMATION TO THIS MANY TONS OF 

NOx: VOC: PM2.5:

NOx 1 3.151 0.067

VOC 0.317 1 0.021

PM2.5 14.833 46.792 1

An example of how the trading mechanism would work follows; If the amount of NOx 

calculated exceeds the budget by 0.75 TPD, then that overage could be offset by trading 2.36 

TPD of excess VOC emissions reductions (e.g 3.151 VOC/1 ton of NOx x 0.75 TPD NOx 

required = 2.36 TPD VOC). In this case, “excess” VOC emission reductions would be those 

beyond what are needed to meet the VOC budget. Similarly 0.050 TPD of directly emitted 

PM2.5 emissions below the budgeted amount could also be traded to the NOx emissions 

category and subtracted from the NOx total to allow NOx to meet its budget. In other words, the 

trading mechanism can be multi-pollutant and multi-directions. It should be noted that the 

trading calculations are performed prior to the final rounding to demonstrate conformity with the 

budgets.
A T T A C H M E N T D

U P D A T E D R A C M / R A C T A N A L Y S I S
Attachment D: Updated RACM/RACT Analysis

D - 1 February 2015

INTRODUCTION

In accordance with the April 25, 2014 final rule “Identification of Nonattainment Classification 

and Deadlines for Submission of State Implementation Plan (SIP) Provisions for the 1997 Fine 

Particle (PM2.5) National Ambient Air Quality Standard (NAAQS) and 2006 PM2.5 NAAQS,” 

(79 FR 31566; June 2, 2014), under Subpart 4, the South Coast Air Basin (Basin) is classified as 

a “moderate” non-attainment area with respect to the 2006 24-hour PM2.5 NAAQS. The EPA 

Final Rule requires that areas classified as moderate nonattainment or higher to develop and 

submit a demonstration that their current air pollution rules fulfill the 24-hour PM2.5 Reasonably 

Available Control Measures (RACM)/ Reasonably Available Control Technology (RACT) 

assessment. The RACM/RACT analysis provides a comparison of the SCAQMD rules and 

regulations governing precursor emission limits to those established by U.S. EPA guidance and 

representative agencies within California and elsewhere throughout the U.S. As a component of 

the 2012 Air Quality Management Plan (AQMP), a RACM/RACT Demonstration for 24-hour 

PM2.5 was submitted to U.S. EPA for inclusion in the California SIP.

This PM2.5 RACM/RACT analysis serves as a supplement to the 2012 AQMP submittal to 

review and where applicable update the SCAQMD toolkit to advance emissions controls to meet 

the current state of the science.

REGULATORY HISTORY

RACM/RACT analyses were incorporated as components of the 2007 and 2012 Air Quality 

Management Plan (AQMP). The 2007 demonstration was a comprehensive analysis conducted 

to identify and select control measures to reduce ozone and particulate precursors NOx, VOC, 

SOx and particulate emissions (to meet the 8-hour ozone and annual PM2.5 standards). The 

2007 RACM/RACT analysis focused on rules, Control Technique Guidelines (CTGs) and 

Alternative Control Techniques (ACTs) adopted through 2006. The analysis identified one 

SCAQMD rule that required additional evaluation. The 2007 AQMP RACM/RACT analysis 

was approved by U.S. EPA for inclusion in the SIP in 2011. 

The 2012 RACM/RACT analysis focused on precursors of PM2.5 (including ammonia, NOx, 

SOX, VOC and particulate matter) to attain the 24-hour average PM2.5 standard. From 2006 

through 2012, 12 CTGs and ACTs were updated. To address this, the 2012 RACM/RACT 

analysis evaluated more than 100 rules and regulations, and 100 control measures developed in 

the 2007-2012 timeframe by other air districts in the nation. Through this analysis, three

additional rules (SCAQMD Rules 1115, 1130 and 1168) were targeted for further evaluation and 

potential rule development. The 2012 RACM/RACT analysis was submitted to U.S. EPA where 

evaluation and approval is pending.
Attachment D: Updated RACM/RACT Analysis

D - 2 February 2015

Subsequently in July 2014, the SCAQMD submitted a RACT SIP update to U.S. EPA as a 

component of the 2016 AQMP. The 2016 RACT analysis built upon the 2007 and 2012 

RACM/RACT assessments focuses on recently adopted rules and regulation by other agencies in 

California and the nation. It is important to note that no additional CTG or ACTs were released 

since the 2012 evaluation. The 2016 RACT analysis evaluated more than 30 rules that were 

recently developed/amended by other ozone nonattainment air districts from September 2012 

through November 2014 and identified six SCAQMD rules that have discrepancies with the 

companion rules at other California agencies. 

Table D-1 summarizes the number of rules assessed between the two prior RACM/RACT 

analyses. Overall, the three assessments concluded that the SCAQMD‟s rules and regulations 

were for the most part equivalent to, or more stringent than other districts‟ rules and regulations 

and their proposed control measures in their respective SIPs. Several of the SCAQMD rules 

identified for evaluation have been amended to address the targeted issue. 

The 2007 RACM/RACT assessments “Appendix VI: Reasonably Available Control Measures 

(RACM) Demonstration” is available at:

http://www.aqmd.gov/docs/default-source/clean-air-plans/air-quality-management-plans/2007-

air-quality-management-plan/2007-aqmp-appendix-vi.pdf?sfvrsn=2

The 2012 RACM/RACT assessments “Appendix VI: Reasonably Available Control Measures 

(RACM) Demonstration” is available at:

http://www.aqmd.gov/docs/default-source/clean-air-plans/air-quality-management-plans/2012-

air-quality-management-plan/final-2012-aqmp-(february-2013)/appendix-vi-final-2012.pdf

The 2016 AQMP RACT Analysis, Governing Board Letter, and Resolution are available at:

http://www.aqmd.gov/docs/default-source/Agendas/Governing-Board/2014/2014-jun6-

031.pdf?sfvrsn=2

RACM/RACT EVALUATION UPDATE

This addendum to the 2012 RACT demonstration provides another update to the corresponding 

analyses discussed above. According to the 2013 Annual Emissions Report (AER), there are 25 

major source facilities of PM2.5 or precursors (> 100 TPY of ROG, NOx, SOx or TSP) in the 

Basin. New sources or sources undergoing modification/relocation after the previous RACT 

determination are subject to Best Available Control Technology (BACT), Best Available Retrofit 

Control Technology (BARCT) or Lowest Achievable Emissions Rate (LAER) requirement, 

which are more stringent than RACT. The current update evaluated rules governing emissions 

limits and modes of operation for the five precursor emissions categories including particulate 

matter, SOx, NOx, VOCs and ammonia (NH3). Table D-2 provides a summary of SCAQMD 
Attachment D: Updated RACM/RACT Analysis

D - 3 February 2015

rules evaluated for PM2.5 precursor emissions control effectiveness. Since the 2012 AQMP 

submittal, the U.S. EPA has not issued new CTGs or ACTs documents for VOC and NOx 

sources. SCAQMD rules applicable to major source facilities were determined RACT in the 

2007/2012 RACM/RACT assessments. Table D-3 provides an updated brief discussion of the 

RACT issues for rules identified for further evaluation in the three demonstrations. In particular, 

the 2016 8-hour ozone RACT update identified six SCAQMD rules that have discrepancies with 

companion rules at other California Agencies. Staff has completed their initial assessment and 

two rules may potentially require updating and amendment:

 Rule 2002 – The current NOx emissions rate limit for cement kilns in SCAQMD is 

slightly higher when compared to the Bay Area AQMD Regulation 9, Rule 13 (2.73 vs, 

2.3 lbs/ton of clinker). The RECLAIM program is currently being evaluated to establish 

new BARCT emissions limits and facility allocations. The proposed new limit (0.5 

lbs/ton clinker) exceeds RACT. The proposed amendment to the NOx RECLAIM is 

underway and is scheduled for adoption in the second quarter of 2015.

 Rule 1115 - Rule 1115 is not as stringent as the 2008 EPA CTG for a few coating 

processes for facilities emitting > 15 lbs/day. Staff will commit to further rule evaluation.

Tables D-4 through D-8, provide the specific RACT analysis for particulate matter, SOx, NOx, 

VOC and NH3 rules and regulations, respectively. In the tables a rule is specifically designated 

to meet RACT if the applicable CTG or ACT is met and has been approved in the 2007 SIP. The 

category defined as RACT Equivalent has been designated to delineate if the rule meets the 

RACT criteria but has minor differences in application and implementation at other agencies. 

Where a rule has been identified as undergoing amendment or has been targeted for further 

evaluation, a brief description of the issues and current/future actions are discussed. As 

previously stated, the SCAQMD‟s rules and regulations were for the most part equivalent to, or 

more stringent than other districts‟ rules and regulations.

Ammonia is currently regulated in the South Coast Air Basin through existing SCAQMD rules 

(see Table D-8) and is included as part of the control strategy in the 2012 AQMP, specifically

control measure BCM-04 (Further Ammonia Reductions from Livestock Waste) listed in Table F1 in Attachment F. Potential ammonia controls are also evaluated under the updated 

RACM/RACT Analysis (see Table D-8). But note that as discussed in Attachment E, ammonia 

controls are much less effective at reducing ambient PM2.5 levels than other precursors. Also 

note that the South Coast Air Basin is currently close to meeting the 24-hour PM2.5 standard 

(see “Air Quality Monitoring Data” on page 4 of the Supplement) and anticipated to meet the 

standard this year (see Attainment Demonstration in Attachment A). Under the General 

Preamble for the Implementation of Title I of the Clean Air Act Amendments of 1990 (57 FR 

13498 at 13560 (April 16, 1992), „„where measures that might in fact be available for 
Attachment D: Updated RACM/RACT Analysis

D - 4 February 2015

implementation in the nonattainment area could not be implemented on a schedule that would 

advance the date for attainment in the area, EPA would not consider it reasonable to require 

implementation of such measures.‟‟ Given that the U.S. Court of Appeals (Nat’l Res. Def. 

Council v. EPA, 706 F.3d 428 (D.C. Cir. 2013)) decided in January 2013 to compel U.S. EPA to 

apply Subpart 4 planning provisions to PM2.5, the resulting withdrawal of the EPA 

Implementation Guidance occurred in June 2013, the re-classification of the South Coast PM2.5 

nonattainment area to Moderate was finalized in July 2014, and the fact that rulemaking takes 

many months to complete, no new potential measures identified in the current RACM/RACT

analysis could possibly be implemented in time to advance the attainment date to 2014. As 

such, no further measures beyond the control strategy in the 2012 AQMP are being proposed at 

this time as a result of the RACM/RACT analysis.

SUMMARY

This analysis updates the three preceding RACM/RACT and RACT analyses. Overall, the 

SCAQMD makes the following general findings: 

1. SCAQMD‟s rules, meet the U.S. EPA‟s criteria for RACT acceptability equaling or 

exceeding applicable CTG and ACT specifications and demonstrating comparable 

emissions limits and requirements to other agency rules.

2. The RACT analysis covers all 5 PM2.5 precursor emissions categories.

3. All new major sources in the Basin are subject to BACT under NSR, which is by 

definition more stringent than RACT.

4. SCAQMD commits to further evaluate the rules identified above for potential emission 

reductions as part of the 2016 AQMP control development.
Attachment D: Updated RACM/RACT Analysis

D - 5 February 2015

TABLE D-1

Summary of Recent SCAQMD RACT and RACM/RACT Analyses

SIP TYPE 

SUBMITTAL STATUS

NUMBER OF 

SCAQMD RULE/

REGULATIONS 

EVALUATED

NUMBER OF 

UPDATED 

CTGS/ACTS 

ASSESSED

RULES 

REQUIRING 

FURTHER 

EVALUATION

2007 RACM/RACT EPA 

Approval 

11/09/11

82 4 Rule 1130

2012 RACM/RACT Pending >100 12 Rule 1130

Rule 1115

Rule 1168

2016 RACT Pending 20 0 Rule 223

Rule 462

Rules 1112/2002

Rules 1118/1150.1

Rule 1130

Rule 1148.1

TABLE D-2

Summary of SCAQMD Rules Evaluated For PM2.5 Precursor Emissions Control 

Effectiveness

PRECURSOR

NUMBER OF 

APPLICABLE 

SCAQMD 

RULES

DIRECT 

SOURCE 

RULES

DISTRICT 

MOBILE

SOURCE 

RULES

PROHIBITIONS

AMENDED 

SINCE 

2006

PM 27 15 5 7 7

SOx 13 6 5 2 1

NOx 22 15 5 2 10

VOC 57 52 5 0 21

NH3 5 5 0 0 3
Attachment D: Updated RACM/RACT Analysis

D - 6 February 2015

TABLE D-3

Updates of the Rules Further Evaluated in the 2012 RACT/RACM Demonstration and 

2016 RACT Analysis

RULE(S) SCAQMD EVALUATION

223 Rule 223 meets RACT through its implementation of technically feasible mitigation 

measures. The focus of the SJVAPCD rule is not applicable in the Basin for dry feed 

operations.

462 Rule 462 is more stringent than the CTG and meets the core requirements for RACT but 

not as stringent as BAAQMD Rule 8-33 with respect to the emissions limit for Class A 

facilities. Staff will commit to further rule evaluation.

1112/2002 Cement Kiln emissions limits were evaluated as part of the 2005 RECLAIM (Rule 2002)

update. RECLAIM is currently being evaluated to establish new BARCT emissions 

limits and facility allocations. The proposed new limits exceed RACT. The RECLAIM 

amendment is projected to be considered for adoption by the second quarter of 2015. 

1115 Rule 1115 is not as stringent as the 2008 EPA CTGs for a few coating processes for 

facilities emitting > 15 lbs/day. The two facilities subject to Rule 1115 have a small 

emission inventory of about 0.02 tpd. Staff will commit to further rule evaluation.

1118/1150.1 Rule 1118 was determined to be RACT from the 2007 SIP targeting flare emissions from 

refinery. SJVAPCD Rule 4311 (exempting municipal landfills) applies to other sources > 

10 TPY. SCAQMD has a small inventory of flare emissions from sources other than 

refinery and landfill (regulated by Rule 1150.1). Rules 1118 is consistent with SJVAPCD 

Rule 4311 and therefore meets RACT.

1130 Rule 1130 was recently amended to reduce fountain solution VOC content to between 16-

85 g/L with optional control device efficiency of 90-95%. The rule meets current CTG 

specifications.

1148.1 Glycol dehydrators in gas and oil production regulated by VCAPCD‟s Rule 71.5 are 

jointly regulated by SCAQMD Rules 1148.1 and Rule 1173 (Control of Volatile Organic 

Compound Leaks and Releases from Components at Petroleum Facilities and Chemical 

Plants) which meet RACT.

1168 Staff has completed its evaluation and is proposing to reduce primer VOC limits to 250 

g/L to meet the CTG. Additional VOC reductions to emissions limits are proposed that 

will exceed RACT. The Rule is expected to be considered 1st quarter 2015.

All the SCAQMD rules in Tables D-4 through D-8 have been SIP approved except for the 

following rules (adoption/last amendment date): Rules 223 (5/2/2014), 444 (1/9/2009), 469 

(2/13/1981), 1110.2 (10/20/1978), 1111 (9/7/2012), 1112 (9/5/2014), 1113 (6/6/1986), 1116.1 

(9/9/2011), 1122 (11/7/2014), 1125 (6/16/2000), 1130 (6/16/2000), 1147 (7/9/2010), 1149 

(10/20/2000), 1153.1 (5/5/2006), 1155 (7/12/2013), 1166 (9/6/2013), 1168 (5/1/2009), 1171 

(3/7/2008), 1183 (5/2/2014), 1186.1 (5/2/2008), 1191 (5/11/2001), 1192 (1/7/2005), 1193 

(5/1/2009), 1194 (3/12/1993), 1195 (6/2/2006). 
Attachment D: Updated RACM/RACT Analysis

D - 7 February 2015

TABLE D-4 

Evaluation of SCAQMD Particulate Matter (PM) Rules and Regulations

RULE 

NO.

TYPE RULE TITLE CURRENT RULE 

REQUIREMENTS

OTHER DISTRICTS’ 2000-2014 

RULES, CONTROL 

MEASURES, U.S. EPA CTGS, 

AND OTHER STUDIES

EVALUATION

1105.1 PM Reduction of PM10 and 

Ammonia Emissions From 

Fluid Catalytic Cracking 

Units

(Adopted 11/7/03)

0.005 grain/dscf PM10 and 10 

ppmv NH3 slip

Meets RACT

1112.1 PM Emissions of Particulate 

Matter from Cement Kilns 

(Amended 12/4/09)

Applicable to gray cement only. 

0.4 lbs PM/tons of kiln feed for 

kilns rating less than 75 tons per 

hour; or 30 lbs per hour for kiln 

rating of 75 tons per hour or 

more.

Note: Companion Rule 1156 has 

more stringent PM limit than this 

rule.

Meets RACT

1133,

1133.1,

1133.2

1133.3

PM Rule 1133 - Composting and 

Related Operations –

General Administrative 

Requirements

(Adopted 1/10/03)

Rule 1133.1 – Chipping and 

Grinding Activities

(Amended 7/8/11)

Rule 1133.2 - Emission 

Reductions from CoComposting Operations

(Adopted January 10, 2003)

Rule 1133.3 - Emission 

Reductions from Greenwaste 

Composting Operations

(Adopted July 8, 2011)

Various performance standards. 

Air pollution control must have 

80% control efficiency or 

greater. Existing operations 

must reduce up to 70% baseline 

VOC and ammonia emissions. 

Baseline emission factors are 

1.78 lbs VOC/ton throughput and 

2.93 lbs NH3/ton throughput.

Rule 1133.3 establishes 

operational best management 

practices (BMPs) for greenwaste 

composting operations. If the 

facility processes more than 

5,000 tons per year of foodwaste, 

any active phase of composting

containing more than 10% 

foodwaste, by weight, must use 

an emission control device with 

San Joaquin Rule 4565 –

Biosolids, Animal Manure, and 

Poultry Litter Operations (Adopted 

3/15/07) and Rule 4566 – Organic 

Material Composting Operations 

(Adopted 8/18/11) have various 

operational requirements for these 

operations as well as the operators 

who landfills, composts, or cocomposts these materials. The 

applicability of Rules 4565/4566 is 

broader than the applicability of 

Rule 1133.3. Rules 4565/4566 

include additional mitigation 

measures to control VOC from 

composting active piles (e.g. 

maintain minimum oxygen 

concentration of 5%, moisture 

content of 40%-70%, carbon to 

nitrogen ratio of 20-1). 

RACT Equivalent.

There is no federal policy or 

guidance describing RACT for this 

source category. 

In April 2012, USEPA determined 

that Rules 1133.1 and 1133.3 fulfill 

RACT requirements. 

Rules 1133 and 1133.2 were 

determined to meet RACT in 

November 2003. San Joaquin 

adopted analogous requirements for 

this source category (Rule 4565) in

2007. 

SCAQMD Rule 1133.2 is more 

stringent than San Joaquin‟s Rule 

4565 for larger co-composting 
Attachment D: Updated RACM/RACT Analysis

D - 8 February 2015

TABLE D-4 (continued)

Evaluation of SCAQMD Particulate Matter (PM) Rules and Regulations

RULE 

NO.

TYPE RULE TITLE CURRENT RULE 

REQUIREMENTS

OTHER DISTRICTS’ 2000-2014 

RULES, CONTROL 

MEASURES, U.S. EPA CTGS, 

AND OTHER STUDIES

EVALUATION

an overall control efficiency of at 

least 80% by weight of VOC.

facilities and less stringent for 

smaller co-composting facilities. 

While SCAQMD Rule 1133.2 

requires either 70 or 80% overall 

emission reductions from all parts of 

composting process, San Joaquin‟s 

Rule 4565 requires add-on controls 

to apply only to the active 

composting phase. Rule 1133.2 also 

has more stringent requirements for 

in-vessel composting.

San Joaquin‟s rule does not address 

chipping & grinding as in Rule 

1133.1.

Based on the above information, 

Rules 1133, 1133.1, 1133.2 and 

1133.3 demonstrate RACT 

equivalency for this source category.
Attachment D: Updated RACM/RACT Analysis

D - 9 February 2015

TABLE D-4 (continued)

Evaluation of SCAQMD Particulate Matter (PM) Rules and Regulations

RULE 

NO. TYPE RULE TITLE CURRENT RULE REQUIREMENTS

OTHER DISTRICTS’ 2000-2014 

RULES, CONTROL 

MEASURES, U.S. EPA CTGS, 

AND OTHER STUDIES

EVALUATION

1137 PM PM10 Reduction From 

Woodworking Operations 

(Adopted 2/1/02)

Good housekeeping practices Rule 1156 contains emission 

standard for baghouses.

Meets RACT

1138 PM Control Of Emissions From 

Restaurant Operations

(Adopted 11/14/97)

Require catalytic oxidizer for 

chain-driven charbroilers. 

Exemption provided for underfired charbroilers and units 

cooking less than 875 lbs/week.

Ventura Rule 74.25 (Adopted 

10/12/04) has equivalent 

requirements as in Rule 1138.

Bay Area Rule 2 of Regulation 6 

(12/5/07) has emission standards of 

0.74 lbs PM10 and 0.32 lbs VOC 

per thousand pounds of meat 

cooked for all chain-driven charbroilers; 1.0 lbs PM10 per 

thousand pounds of meat cooked 

for all under-fired charbroilers with 

combined total grill surface area of 

at least 10 square feet. Most 

BAAQMD under-fired 

charbroilers facilities are too 

small to trigger the under-fired 

charbroilers requirements. 

RACT Equivalent

The BAAQMD reported costeffective values of $17,300/ton of 

VOC and PM removed for HEPA 

filters and $19,500/ton of VOC and 

PM removed for electrostatic

precipitators. These cost 

effectiveness values go beyond

RACT. 

1140 PM Abrasive Blasting

(Amended 8/2/85)

Visibility standard Meets RACT

1155 PM Particulate Matter Control 

Devices

(Amended 5/2/14)

PM standards for PM control 

devices at 0.01 gr/dcsf for 

existing large baghouses >7500 

square feet. Good operational 

practices to reduce PM emissions 

Meets RACT
Attachment D: Updated RACM/RACT Analysis

D - 10 February 2015

TABLE D-4 (continued)

Evaluation of SCAQMD Particulate Matter (PM) Rules and Regulations

RULE 

NO.

TYPE RULE TITLE CURRENT RULE 

REQUIREMENTS

OTHER DISTRICTS’ 2000-2014 

RULES, CONTROL 

MEASURES, U.S. EPA CTGS, 

AND OTHER STUDIES

EVALUATION

1156 PM PM10 Emission Reductions 

from Cement Manufacturing 

Facilities

(Amended 3/6/09)

PM standards for PM control 

devices (0.01 gr/dcsf for existing 

and 0.005 gr/dcsf for new 

devices). Good operational 

practices to reduce PM emissions 

from aggregate and related 

operations

Meets RACT

1157 PM PM10 Emissions Reductions 

from Aggregate and Related 

Operations

(Amended 9/8/06)

Good operational practices to 

reduce PM emissions from 

aggregate and related operations

Meets RACT

1158 PM Storage, Handling and 

Transport of Petroleum Coke

(Amended 7/11/08)

Reduce PM emissions through 

good management practices

Meets RACT

1186 PM PM10 Emissions from Paved 

and Unpaved Roads, and 

Livestock Operations

(Adopted 7/11/08)

Good management practices Meets RACT

1186.1 PM Less Polluting Sweepers 

(Amended 1/9/09)

Require operators to purchase 

less polluting or alternative 

fueled street sweepers.

Meets RACT
Attachment D: Updated RACM/RACT Analysis

D - 11 February 2015

TABLE D-4 (concluded)

Evaluation of SCAQMD Particulate Matter (PM) Rules and Regulations

RULE 

NO.

TYPE RULE TITLE CURRENT RULE 

REQUIREMENTS

OTHER DISTRICTS’ 2000-2014 

RULES, CONTROL 

MEASURES, U.S. EPA CTGS, 

AND OTHER STUDIES

EVALUATION

404, 

468, 

and 

469

PM Rule 404 – Particulate 

Concentration

(Amended 2/7/86)

Rule 468 – Sulfur Recovery 

Units

(Amended 10/8/76)

Rule 469 – Sulfuric Acid 

Units

(Amended 2/13/81)

PM limits vary from 0.01gr/dscf 

to 0.19 gr/dscf in Rule 404

depending on exhaust flow rates.

Sulfuric acid mist limit in Rule 

469 is 0.3 lbs per ton of acid 

produced (approximately 0.1 

gr/dscf)

Rule 468 for sulfur recovery 

units does not contain any PM 

standard.

Bay Area, Regulation 6, Rule 1 

(Adopted 12/5/07) contains the 

following limits:

 PM limit is 0.15 gr/dscf

 Sulfuric Acid Manufacturing 

Plants: limit sulfur trioxide or 

sulfuric acid mist, or both, 

expressed as 100% sulfuric acid, 

to 0.04 gr/dscf

 Sulfur Recovery Units: limit 

sulfur trioxide or sulfuric acid 

mist, or both, expressed as 100% 

sulfuric acid, to 0.08 gr/dscf

RACT Equivalent

444 All Open Burning

(Amended 7/12/13)

Contains requirements and 

prohibitions for open burning to 

minimize emissions and smoke 

impacts to the public.

San Joaquin Valley Rule 4103 

(Amended 4/15/10) contains 

additional best management 

practices compared to Rule 444 

such as best management practices 

to control open burning of weeds.

Bay Area, Reg 5, sets requirements 

for open burning, and was to forbid 

recreational burning during 

curtailment periods.

Meets RACT

445 PM Wood Burning Devices

(Amended 5/3/13)

Contains requirements for wood 

burning devices to minimize 

emissions and smoke impacts to 

the public.

San Joaquin Valley Rule 4901 

comparable to Rule 445.

Meets RACT
Attachment D: Updated RACM/RACT Analysis

D - 12 February 2015

TABLE D-5

Evaluation of SCAQMD Sulfur Oxides (SOx) Rules and Regulations

RULE 

NO.

TYPE RULE TITLE CURRENT RULE 

REQUIREMENTS

OTHER DISTRICTS’ 2000-2014 

RULES, CONTROL 

MEASURES, U.S. EPA CTGS, 

AND OTHER STUDIES

EVALUATION

1116.1 SOx Lightering Vessel Operations 

– Sulfur Content of Bunker 

Fuel

(Adopted 10/20/78)

0.5% sulfur by weight Meets RACT

1118 All Refinery Flares

(Amended 11/4/05)

 Minimize flare emissions & 

require smokeless operations

 Specify SO2 gradually 

decreasing performance 

target to less than 0.5 tons 

per million barrels of crude 

by 2012.

 If the performance target is 

exceeded, the operator must 

1) pay mitigation fee; or 2) 

submit a Flare Mitigation 

Plan to reduce emissions.

 Require Cause Analysis for 

event exceeding 100 lbs 

VOC, 500 lbs of SO2, or 

500,000 scfm of vent gas, 

excluding planned shutdown, 

startup and turnarounds

 Require 160 ppmv H2S, 3 

hour average by 1/1/09, and 

no limits for NOx, VOC, PM 

and CO.

U.S. EPA suggested the SCAQMD

to further re-evaluate Rule 1118 

(FR Vol 76 No 217, Nov 9, 2011, 

CBE comments).

San Joaquin Valley Rule 4311 

(Amended 6/18/09) has VOC/NOx 

limits for ground-level enclosed 

flares; SO2 Targets (1.50 

tons/million barrels of crude by 

2011, and 0.5 tons/million barrels 

by 2012); Flare Minimization Plan 

for refinery flares more than 5 

mmbtu/hr; and operational 

requirements for all flares that 

have potential to emit more than 10 

tons/yr VOC and more than 10 

tons/yr of NOx.

Bay Area Rule 12-12 (Adopted 

4/5/06) does not specify a 

declining SO2 target and does not 

contain a mitigation fee option.

Rule 1118 was determined to be 

RACT from the 2007 SIP targeting 

flare emissions from refinery. 

SJVAPCD Rule 4311 (exempting 

municipal landfills) applies to other 

sources > 10 TPY. SCAQMD has a 

small inventory of flare emissions 

from sources other than refinery and 

landfill. Rules 1118 is consistent 

with SJVAPCD Rule 4311.

1119 SOx Petroleum Coke Calcining 

Operations – Oxides of 

Sulfur

(Adopted 3/2/79)

Reduce SOx by 80% Meets RACT
Attachment D: Updated RACM/RACT Analysis

D - 13 February 2015

TABLE D-5 (continued)

Evaluation of SCAQMD Sulfur Oxides (SOx) Rules and Regulations

RULE 

NO.

TYPE RULE TITLE CURRENT RULE 

REQUIREMENTS

OTHER DISTRICTS’ 2000-2014 

RULES, CONTROL 

MEASURES, U.S. EPA CTGS, 

AND OTHER STUDIES

EVALUATION

2002 SOx RECLAIM

(Amended 11/5/10)

Include facility allocations for 

SOx for RECLAIM facilities. 

BARCT Emissions Limits:

Calciner, Petroleum Coke

 10 ppmv (0.11 lbs/ton 

coke)

Cement Kiln

 5 ppmv (0.04 lbs/ton 

clinker)

Coal-Fired Boiler

 5 ppmv (95% reduction)

Container Glass Melting Furnace

 5 ppmv (0.03 lbs/ton glass)

Diesel Combustion

 15 ppmv as required under 

Rule 431.2

Fluid Catalytic Cracking Unit

 5 ppmv (3.25 lbs/thousand 

barrels feed)

Refinery Boiler/Heater

 40 ppmv (6.76 lbs/mmscft)

Sulfur Recovery Units/Tail Gas

 5 ppmv for combusted tail 

gas (5.28 lbs/hour)

Sulfuric Acid Manufacturing

 10 ppmv (0.14 lbs/ton acid 

produced) 

Other Districts do not have 

RECLAIM. SCAQMD has set 

most stringent BARCT for SOx

sources in the 2010 RECLAIM 

Amendments.

Exceeds RACT
Attachment D: Updated RACM/RACT Analysis

D - 14 February 2015

TABLE D-5 (concluded)

Evaluation of SCAQMD Sulfur Oxides (SOx) Rules and Regulations

RULE 

NO.

TYPE RULE TITLE CURRENT RULE 

REQUIREMENTS

OTHER DISTRICTS’ 2000-2014 

RULES, CONTROL 

MEASURES, U.S. EPA CTGS, 

AND OTHER STUDIES

EVALUATION

431.1 SOx Sulfur Content Gaseous 

Fuels

(Amended 6/12/98)

H2S Limits:

Natural gas (16 ppmv)

Refinery Gas (40 ppmv )

Landfill Gas (150 ppmv)

Sewage Gas (40 ppmv)

Other Gas (40 ppmv)

Meets RACT

431.2 SOx Sulfur Content Liquid Fuels

(Amended 9/15/2002)

Limit: 15 ppm by weight Meets RACT

1101 SOx Secondary Lead Smelters –

Sulfur Oxides

(Amended 10/7/77)

200 ppmv SOx and 4.2 lbs SOx 

per ton process weight

Meets RACT

1105 SOx Fluid Catalytic Cracking 

Units – Oxides of Sulfur

|(Amended 9/1/84)

RECLAIM BARCT limit:

Fluid Catalytic Cracking Unit

 5 ppmv (3.25 lbs/thousand 

barrels feed)

Following the U.S. EPA consent 

decrees, several refineries in the 

SCAQMD achieved emission 

levels as low as 25 ppmv (365 day 

average) and 50 ppmv (7 day avg)

Other Districts do not have 

RECLAIM. SCAQMD has set 

most stringent BARCT for SOx 

sources in the 2010 RECLAIM 

Amendments

Meets RACT
Attachment D: Updated RACM/RACT Analysis

D - 15 February 2015

TABLE D-6

Evaluation of SCAQMD NOx Rules and Regulations

RULE 

NO.

TYPE RULE TITLE CURRENT RULE 

REQUIREMENTS

OTHER DISTRICTS’ 2000-2014 

RULES, CONTROL 

MEASURES, U.S. EPA CTGS, 

AND OTHER STUDIES

EVALUATION

1109 NOx Emissions of Oxides of 

Nitrogen from Boilers and 

Process Heaters – Petroleum 

Refineries

(Amended 8/5/88)

0.03 lbs/mmBTU of heat input 

(~25 ppmv). Subsumed by 

RECLAIM. RECLAIM 

(amended 1/2005 version) used 5 

ppmv for >110 mmbtu/hr and 25 

ppmv for units 40-100 mmbtu/hr.

San Joaquin current Rule 4306 

limits are 5 ppmv for refinery units 

> 110 mmbtu/hr, 25 ppmv for units 

> 65 mmbtu/hr, 30 ppmv for units 

< 20 mmbtu/hr. For other units, 9 

ppmv (or 6 ppmv) for units >20 

mmbtu/hr and 15 ppmv (or 9 

ppmv) for units from 5-20 

mmbtu/hr.

Rule 2002 is currently being 

evaluated with targeted NOx limits 

of 2 ppmv for all units > 40 mmbtu.

1110.2 NOx Emissions from Gaseous and 

Liquid Fueled Engines

(Amended 9/7/12)

Rule 1110.2 has NOx, VOC, CO 

limits for all stationary and 

portable engines over 50 brake 

horse power (bhp).

In general, the limits applicable 

to 1) stationary, non-emergency

engines by 7/1/2011, and 2) 

biogas (landfill and digester gas) 

engines by 7/1/2012 are:

 11 ppmv NOx

 30 ppmv VOC

 250 ppmv CO

San Joaquin Valley Rule 4702 

(Amended 8/19/11) has NOx, 

VOC, CO and SOx limits for 

engines rated over 25 bhp.

For engines over 50 bhp:

- By 1/1/2017, the limits for 

spark-ignited engines are:

 11 ppmv NOx

 250 ppmv VOC (rich-burn) 

and 750 ppmv VOC (lean 

burn), and

 2000 ppmv CO 

Meets RACT
Attachment D: Updated RACM/RACT Analysis

D - 16 February 2015

TABLE D-6 (continued)

Evaluation of SCAQMD NOx Rules and Regulations

RULE 

NO.

TYPE RULE TITLE CURRENT RULE 

REQUIREMENTS

OTHER DISTRICTS’ 2000-2014 

RULES, CONTROL 

MEASURES, U.S. EPA CTGS, 

AND OTHER STUDIES

EVALUATION

1110.2

(Cont.)

NOx Limits for new non-emergency 

engines driving electrical 

generators are:

 0.07 lbs NOx per MW-hr

 0.20 lbs CO per MW-hr

 0.10 lbs VOC per MW-hr 

NOx limits for low usage biogas 

engines:

 36 ppmv, engines ≥ 500 bhp

45 ppmv, engines < 500 bhp

VOC and CO limits for low 

usage biogas engines:

 40 ppmv VOC, landfill gas

 250 ppmv VOC, digester gas

 2000 ppmv CO.

Portable and agricultural engines 

are not subject to the general 

limits listed above.

Many of Rule 1110.2 engines are 

in RECLAIM, and RECLAIM 

will be amended to incorporate 

feasible BARCT.

- Engines used in agricultural 

operations (AO), or fueled with 

waste gas, or limited used, or 

cyclic loaded and field gas 

fueled are subject to higher 

limits than the above

- In general, all compression 

ignited engines must meet EPA 

Tier 4 standards.

Engines between 25 bhp - 50 bhp, 

non agricultural operations (AO), 

must meet federal standards 

40CFR Part 60 Subpart IIII and 

JJJJ.

The SOx limits are: 1) Natural gas, 

propane, butane, LPG, or 

combination, or 2) 5 grains/100 scf 

for gaseous fuel, or 3) 15 ppmv 

liquid fuel, or 4) CA reformulated 

gasoline for spark-ignited engines, 

or 5) CA reformulated diesel for 

compression ignited engines, or 6) 

95% control.

1111 NOx NOx Emissions from 

Natural-Gas-Fired, Fan-Type 

Central Furnaces

(Amended 9/5/14)

40 nanograms per joule heat 

output until 2015. A lower 

standard of 14 ng/J is required 

with staggering compliance dates 

from 2015-2018.

Meets RACT
Attachment D: Updated RACM/RACT Analysis

D - 17 February 2015

TABLE D-6 (continued)

Evaluation of SCAQMD NOx Rules and Regulations

RULE 

NO.

TYPE RULE TITLE CURRENT RULE 

REQUIREMENTS

OTHER DISTRICTS’ 2000-2014 

RULES, CONTROL 

MEASURES, U.S. EPA CTGS, 

AND OTHER STUDIES

EVALUATION

1112 NOx Emissions of Oxides of 

Nitrogen from Cement Kilns 

(Amended 6/6/86)

Applicable to gray cement only. 

11.6 lbs/ton clinker averaged 

over 24 hours and 6.4 lbs/ton 

clinker averaged over 30 days. 

Subsumed by RECLAIM.

RECLAIM, amended 1/05 

version, had no recommendation 

for cement kiln BARCT. 

However, RECLAIM BARCT 

analysis is an on-going process 

and will be evaluated every three 

years.

North Central Texas proposes to 

reduce NOx from cement kilns to 

80%-85% using technology such 

as SCR or LoTOx

Rule 2002 is currently being 

evaluated with targeted NOx limits 

of 0.5 lb/ton clinker pulled.

1117 NOx Emissions of Oxides of 

Nitrogen from Glass Melting 

Furnaces

(Amended 1/6/84)

4 lb/NOx per ton of glass pulled. 

Flat glass and fiberglass melting 

furnaces are exempt.

Many of these R1117 units are in 

RECLAIM. RECLAIM 

(Amended 1/05 version) had no 

BARCT recommendation for this 

class. However, BARCT 

analysis is an on-going process 

and will be reevaluated every 

three years.

San Joaquin Rule 4354 – Glass 

Melting Furnaces (Amended 

8/17/06) have NOx, CO, VOC, 

SOx limits. For NOx, 4 lb/ton for 

container glass and fiberglass and 

7 lb/ton - 9 lb/ton for flat glass 

melting furnaces. 

Since there is a potential to lower 

the standards through BARCT (e.g. 

scrubber and SCR), San Joaquin 

proposes to lower the standards for 

all glass furnaces in their 2007 

AQMP. 

Rule 2002 is currently being 

evaluated with targeted NOx limits 

of

 0.5 lb/ton container glass 

pulled, 

 1.28 lb/ton glass pulled in a 

sodium silicate furnace.

1121 NOx Control of Nitrogen Oxides 

from Residential Type, 

Natural-Gas-Fired Water 

Heaters

(Amended 9/3/04)

15 ppmv at 3% O2, dry input (or 

10 ng/j output) for all stationary 

water heaters; and 55 ppmv at 

3% O2, dry input (40 ng/j 

output) for mobile water heaters.

Other Districts‟ plans propose to 

accelerate replacements of old 

water heaters with electric units or 

new highly-efficient loweremitting water heaters with the use 

of incentives.

Meets RACT
Attachment D: Updated RACM/RACT Analysis

D - 18 February 2015

TABLE D-6 (continued)

Evaluation of SCAQMD NOx Rules and Regulations

RULE 

NO.

TYPE RULE TITLE CURRENT RULE 

REQUIREMENTS

OTHER DISTRICTS’ 2000-2014 

RULES, CONTROL 

MEASURES, U.S. EPA CTGS, 

AND OTHER STUDIES

EVALUATION

1134 NOx Emissions of Oxides of 

Nitrogen from Stationary 

Gas Turbines

(Amended 8/8/97)

Standard = Reference Limit x

(Unit Efficiency/25%), where 

reference limit depends on size 

of units, varying from 9 ppmv 

for units rating at equal to or 

larger than 10MW to 25 ppmv 

for units rating from 0.3 MW to 

less than 2.9 MW.

RECLAIM, amended 1/2005 

version, indicated that 5 ppmv 

was achieved in practice but not 

cost effective, therefore did not 

propose BARCT. This analysis 

may need to be revised based on 

new information. RECLAIM 

BARCT is an on-going process 

that is planned to be reviewed 

every 3 years.

Sacramento Rule 413 (Amended 

03/24/05) has standards from 9 

ppmv – 25 ppmv depending on 

size of units, but are independent 

on equipment efficiency.

San Joaquin Rule 4703 (Amended 

8/17/06) has standards from 5 

ppmv – 50 ppmv depending on 

size of units. Combined cycle 

units > 10 MW has limit of 3 

ppmv. San Joaquin is now 

proposing to revisit its current rule 

for further reduction. 

Ventura Rule 74.9 (Amended 

11/08/05) has standards from 25 –

125 ppmv depending on fuel type 

but are independent from 

equipment size and efficiency. 

Control efficiency 90% - 96% 

control efficiency. In addition, all 

units have to meet 20 ppmv NH3. 

Rule 2002 is currently being 

evaluated with targeted NOx limits 

of 2 ppmv for all units.

1135 NOx Emissions of Oxides of 

Nitrogen From Electric 

Power Generating Systems 

(Amended 7/19/91)

Mass emission limits and 

emission reduction goals for 

utility boilers. Only City of 

Glendale is subject to Rule 1135, 

which is allowed to meet 0.2 

lb/MW-hr (or a daily mass limit 

of 390 lb NOx per day, or an 

annual limit of 35 tons per year).

Ventura Rule 59 (amended 

7/15/97) requires:

 0.1 lb NOx/MW-Hr for utility 

boilers and

 0.04 lb/MW-hr for auxiliary 

boilers.

San Joaquin Rule 4306 – Phase 3 

(amended 3/17/2005) requires 

Rule 2002 is currently being 

evaluated with targeted NOx limits 

of 2 ppmv for all units.
Attachment D: Updated RACM/RACT Analysis

D - 19 February 2015

TABLE D-6 (continued)

Evaluation of SCAQMD NOx Rules and Regulations

RULE 

NO.

TYPE RULE TITLE CURRENT RULE 

REQUIREMENTS

OTHER DISTRICTS’ 2000-2014 

RULES, CONTROL 

MEASURES, U.S. EPA CTGS, 

AND OTHER STUDIES

EVALUATION

1135

(Cont.)

NOx Other utility boilers are in 

RECLAIM subject to declining 

NOx allocations which were 

determined based on a level of 7 

ppmv (about 0.07 lb/MW-hr 

assuming a heat rate of 8130 

Btu/kw-hr), and are operated at 

various BARCT levels from 5 

ppmv – 30 ppmv.

boilers more than 20 mmbtu/hr to 

comply with the following options:

 Standard option of 9 ppmv (or 

0.011 lb/mmbtu) complied by 

2005-2007, or 

 Enhanced option of 6 ppmv (or 

0.007 lb/mmbtu) complied by 

2006-2008. (Assuming a heat 

rate of 8130 Btu/kw-hr, 6 

ppmv is about 0.06 lb/MW-hr.)

1146 NOx Emissions of Oxides of 

Nitrogen from Industrial, 

Institutional and Commercial 

Boilers, Steam Generators, 

and Process Heaters 

(Amended 11/1/2013)

Applicable to units rating of 

more than 5 mmbtu/hr.

Current NOx limits:

 For digester gas: 15 ppmv 

 For landfill gas: 25 ppmv

 For refinery gas: 30 ppmv 

(the 2008 amendment did not 

revise limits for refinery gas)

 For other types of fuels:

5 ppmv for ≥75 mmbtu/hr, 

natural gas; 30 ppmv for ≥75 

mmbtu/hr, other fuels; and 5 

or 9 ppmv for 20–75

mmbtu/hr units

CO limit: 400ppmv

Sacramento Rule 411 (Amended 

10/27/05) limits for gaseous fuel 

are 9 ppmv for units greater than 

20 mmbtu/hr, and 15 ppmv for 

units from 5 to 20 mmbtu/hr.

San Joaquin Rule 4306 (Amended 

10/18/08) has the following limits:

NOx limits:

 30 ppmv for 5-65 mmbtu/hr 

units using refinery gas. For 

units from 40 – 100 mmbtu/hr, 

refer to the comparison under 

Rule 1109

 For other types of fuels:

9 ppmv for >20 mmbtu/hr units; 

15 ppmv for ≤20 mmbtu/hr units

(6 – 9 ppmv for enhanced 

options)

 Other units: 15 – 30 ppmv CO 

limit: 400 ppmv.

RACT Equivalent
Attachment D: Updated RACM/RACT Analysis

D - 20 February 2015

TABLE D-6 (continued)

Evaluation of SCAQMD NOx Rules and Regulations

RULE 

NO.

TYPE RULE TITLE CURRENT RULE 

REQUIREMENTS

OTHER DISTRICTS’ 2000-2014 

RULES, CONTROL MEASURES, 

U.S. EPA CTGS, AND OTHER 

STUDIES

EVALUATION

1146

(Cont.)

NOx Many Rule 1146 units are in 

RECLAIM. RECLAIM 

(Amended 1/05 version) contains 

the following NOx limits:

 For refinery gas:

5 ppmv for units > 110 

mmbtu/hr; and 25 ppmv for 

units < 110 mmbtu/hr units

 For other units: 

9 ppmv for units > 20 mmbtu/hr; 

and 12 ppmv for units ≥ 5 

mmbtu/hr

San Joaquin Valley further reduces 

NOx, CO, SO2 and PM10 emissions by 

adopting Rule 4320 on 10/16/08. The 

limits in Rule 4320 are:

NOx limits:

 For refinery gas:

5 – 6 ppmv for units between 20-110 

mmbtu/hr; 6 – 9 ppmv for units 

between 5 - 20 mmbtu/hr; and 9 

ppmv for units firing of less than 

50% by vol PUC quality gas. Refer 

to the comparison under Rule 1109 

for 40 mmbtu/hr units and above 

using refinery gas.

 For oil field generators:

5 - 7 ppmv for units greater than 20 

mmbtu/hr; 6 – 9 ppmv for units larger 

than 5 but less than 20 mmtu/hr; and 

9 ppmv for units firing of less than 

50% by vol PUC quality gas

 For low usage units: 9 ppmv

 For units at a wastewater treatment 

facilities firing on less than 50% by 

vol PUC quality gas: 9 ppmv

 For other units: 5 – 7 ppmv for units 

larger than 20 mmbtu/hr; and 6 – 9 

ppmv for units between 5 mmbtu/hr 

and 20 mmbtu/hr
Attachment D: Updated RACM/RACT Analysis

D - 21 February 2015

TABLE D-6 (continued)

Evaluation of SCAQMD NOx Rules and Regulations

RULE 

NO.

TYPE RULE TITLE CURRENT RULE 

REQUIREMENTS

OTHER DISTRICTS’ 2000-2014 

RULES, CONTROL MEASURES, 

U.S. EPA CTGS, AND OTHER 

STUDIES

EVALUATION

1146

(Cont.)

NOx Compliance may be mitigated with 

annual emission fees.

1146.1 NOx Emissions of Oxides of 

Nitrogen from Small 

Industrial, Institutional, and 

Commercial Boilers, Steam 

Generators, and Process 

Heaters

(Amended 11/1/13)

Applicable to units rating from

2 mmbtu/hr to 5 mmbtu/hr.

NOx limits:

 Atmospheric Units: 12 ppmv

 Digester gas: 15 ppmv

 Landfill gas: 25 ppmv 

 All others: 9 ppmv 

CO limit: 400 ppmv.

Many Rule 1146.1 units are in 

RECLAIM, and RECLAIM 

(Amended 1/05 version) BARCT 

analysis recommended 12 ppmv 

for less than 5 mmbtu/hr units 

based on ultra low NOx

technology that is achieved in 

practice. 

RECLAIM (Amended in 2005) 

has a limit of 12 ppmv NOx for 

boilers in this size range.

Bay Area Rule 9-11 (Amended 

5/17/00) has following limits for 

boilers using gaseous fuel 1) 10 

ppmv for boilers with rated input 

greater than 1.75 mmbtu/hr, 2) 25 

ppmv for boilers from 1.5-1.75 

mmbtu/hr, 3) 30 ppmv for boilers 

less than 1.5 million btu/hr. Nongaseous fuel combustion devices 

have higher limits than gaseous 

fuel devices.

San Joaquin Rule 4307 (Amended 

5/19/2011) has the following limits:

NOx limits:

For New or Replacement Units:

Atmospheric Units: 12 ppmv, and 

Non-Atmospheric Units: 9 ppmv

-For Retrofit Units: 30 ppmv burning 

gaseous fuels; and 40 ppmv burning 

liquid fuels

Sulfur limits for SO2: 

-For natural gas, propane, butane, or 

LPG: 5 grains of total sulfur per 100 

scf, or 9 ppmv SO2, or 95% control

-For liquid fuels: 15 ppmv sulfur

RACT Equivalent
Attachment D: Updated RACM/RACT Analysis

D - 22 February 2015

TABLE D-6 (continued)

Evaluation of SCAQMD NOx Rules and Regulations

RULE 

NO.

TYPE RULE TITLE CURRENT RULE 

REQUIREMENTS

OTHER DISTRICTS’ 2000-2014 

RULES, CONTROL 

MEASURES, U.S. EPA CTGS, 

AND OTHER STUDIES

EVALUATION

1146.2 NOx Emissions of Oxides of 

Nitrogen from Large 

Water Heaters and Small 

Boilers (Amended 5/5/06)

Applicable to units less than 2 

mmbtu/hr. 

Current limits are:

 20 ppmv for units from 400,000 

btu/hr – 2 mmbtu/hr

 55 ppmv for units rating less 

than 400,000 btu/hr

San Joaquin Valley Rule 4308, 

(Amended 11/14/13) requires:

 20 ppmv for units used PUC 

gas from 75,000 btu/hr – 2 

mmbtu/hr

 30 ppmv for units from 400,000 

btu/hr - 2 mmbtu/hr used other 

types of fuels

 77 ppmv for units rating from 

75,000 btu/hr – 400,000 btu/hr 

used other types of fuels

Meets RACT

1147 NOx NOx Emissions from 

Miscellaneous Sources

(Amended 9/9/11)

Current limits are:

Gas Fired Equipment:

 60 ppmv for units operating at 

temperatures ≥ 1200 oF 

 30 or 60 ppmv for units 

operating at temperatures < 

1200 oF.

 40 ppmv for asphalt 

Liquid Fuel fired Equipment:

 40 ppmv for units operating at 

temperatures < 1200 o F

 60 ppmv for units operating at 

temperatures ≥ 1200 o F 

 Units less than 1 lb/day 

compliance delayed until 2017

Mitigation fee option for delayed 

compliance for multiple units

San Joaquin Valley APCD Rule 

4309 (2005) equivalent for asphalt.

40 ppmv for ovens, dehydrators 

and dryers with no temperature 

stratification

RACT Equivalent

Cooking ovens, dry roasters removed 

from rule applicability to new Rule 

1153.1 (11/7/14)

SCAQMD Rule 1147 varies in 

stringency when compared to other 

Districts‟ requirements. For the 

majority of the categories, Rule 1147

is as stringent as or more stringent 

than the other Districts‟ rules.
Attachment D: Updated RACM/RACT Analysis

D - 23 February 2015

TABLE D-6 (continued)

Evaluation of SCAQMD NOx Rules and Regulations

RULE 

NO.

TYPE RULE TITLE CURRENT RULE 

REQUIREMENTS

OTHER DISTRICTS’ 2000-2014 

RULES, CONTROL 

MEASURES, U.S. EPA CTGS, 

AND OTHER STUDIES

EVALUATION

1153.1 NOx Emissions of Oxides of 

Nitrogen from Commercial 

Food Ovens

(Adopted 11/7/14)

 40 ppmv for units operating 

at temperatures < 500 oF

 60 ppmv for units operating 

at temperatures ≥ 500 oF 

 CO capped at 800 ppmv

 Exemption < 1 lb/day and 

low use sources

 20 year equipment life

 Mitigation fee for alternate 

compliance plan

Meets RACT

1159 NOx Nitric Acid Units – Oxides 

of Nitrogen

(Amended 12/6/85)

 450 ppmv 15 min avg, or

 237 ppmv, 60 min avg; or

 3 lbs/ton acid produced, 60 

min average.

Meets RACT

1191 All Light and Medium Duty 

Fleet Vehicles

(Amended 6/16/00)

Require public fleet to acquire 

new low emitting gasoline or 

alternative fuel light and medium 

duty vehicles.

Meets RACT

1192 All Clean On-Road Transit 

Buses

(Amended 6/16/00)

Require public fleet to acquire 

new low emitting or alternative 

fuel heavy duty vehicles.

Meets RACT

1193 All Clean On-Road Residential 

/Commercial Refuse

Collection Vehicles

(Amended 7/9/10)

Acquire new low emitting refuse 

collection vehicles.

Meets RACT
Attachment D: Updated RACM/RACT Analysis

D - 24 February 2015

TABLE D-6 (concluded)

Evaluation of SCAQMD NOx Rules and Regulations

RULE 

NO.

TYPE RULE TITLE CURRENT RULE 

REQUIREMENTS

OTHER DISTRICTS’ 2000-2014 

RULES, CONTROL 

MEASURES, U.S. EPA CTGS, 

AND OTHER STUDIES

EVALUATION

1194 All Commercial Airport Ground 

Access

(Amended 10/20/00)

Acquire new low emitting 

vehicles that are used for 

passenger transportation in/out 

airports.

Meets RACT

1195 All Clean On-Road School 

Buses

(Amended 5/5/06)

Acquire new low emitting school 

buses.

Meets RACT

2002 NOx, RECLAIM

(Amended 11/5/10)

Include facility allocations for 

NOx for RECLAIM facilities

Other Districts do not have 

RECLAIM, refer to individual 

rules such as Rule 1146, 1146.1, 

1110.2 etc.

BARCT review currently underway.

Rule Forecast: Second Quarter 2015 

444 NOx Open Burning

(Amended 7/12/13)

Contains requirements and 

prohibitions for open burning to 

minimize emissions and smoke 

impacts to the public.

San Joaquin Valley Rule 4103 

(Amended 4/15/10) contains 

additional best management 

practices compared to Rule 444 

such as best management practices 

to control open burning of weeds.

Meets RACT

445 NOx Wood Burning Devices 

(Amended 5/3/13)

Contains requirements for wood 

burning devices to minimize 

emissions and smoke impacts to 

the public. 

Restrictis burning during the 

forecasted episodic curtailment 

periods. 

San Joaquin Valley Rule 4901 

(Amended 9/18/14) comparable to 

Rule 445.

Meets RACT
Attachment D: Updated RACM/RACT Analysis

D - 25 February 2015

TABLE D-7

Evaluation of SCAQMD VOC Rules and Regulations

RULE 

NO.

TYPE RULE TITLE CURRENT RULE 

REQUIREMENTS

OTHER DISTRICTS’ 2000-2014 

RULES, CONTROL 

MEASURES, U.S. EPA CTGS, 

AND OTHER STUDIES

EVALUATION

1102 VOC Petroleum Solvent Dry 

Cleaners

(Amended 11/17/00)

Maximum usage 15 gals per 

month and various equipment 

specifications and operating 

requirements. Exemptions 

provided for certain types of dry 

cleaning provided that detergents 

and additives must be less than 

50 g/L VOC.

Meets RACT

1103 VOC Pharmaceuticals and 

Cosmetics Manufacturing

(Amended 3/12/99)

For reactors, distillation 

columns, crystallizers, or 

centrifuges: 15 lbs/day VOC or 

use surface condensers. For air 

dryers: 90% control efficiency 

or 33 lbs/day VOC. Also include 

other various operating 

requirements.

Meets RACT

1104 VOC Wood Flat Stock Coating 

Operation

(Amended 8/13/99)

2.1 lbs/gal, less water and 

exempt solvent. In lieu of VOC 

limit, use control device having 

95% control efficiency (or 50 

ppmv outlet) and 90% collecting 

efficiency 

Meets RACT

1106 VOC Marine Coating Operations

(Amended 1/13/95)

Coating-specific emission limits 

from 275 – 780 g/L. In lieu of 

complying with specific 

emission limits, operator can use 

air pollution control system with 

at least 85% efficiency. Solvent 

cleaning operations must comply 

with Rule 1171.

Ventura Rule 74.24 (Amended 

9/11/12) generally has the same 

limits as South Coast Rule 1106, 

except the limit for special 

marking of items such as flight 

decks, ship numbers is 420 g/L 

(490 g/L in Rule 1106)

Meets RACT
Attachment D: Updated RACM/RACT Analysis

D - 26 February 2015

TABLE D-7 (continued)

Evaluation of SCAQMD VOC Rules and Regulations

RULE 

NO.

TYPE RULE TITLE CURRENT RULE 

REQUIREMENTS

OTHER DISTRICTS’ 2000-2014 

RULES, CONTROL 

MEASURES, U.S. EPA CTGS, 

AND OTHER STUDIES

EVALUATION

1106

(Cont.)

Bay Area Rule 8-43 (Amended 

10/16/02) generally has the same 

limits as South Coast Rule 1106, 

except it has lower limit for 

pretreatment wash primer at 420 

g/L (780 g/L in Rule 1106)

1106.1 VOC Pleasure Craft Coating 

Operations

(Amended 2/12/99)

Coating-specific emission limits 

from 340 – 780 g/L. Solvent 

cleaning operations must comply 

with Rule 1171.

San Joaquin Valley‟s Rule 4603 

(Amended 9/17/09) limit for teak 

primer, wood sealer, and clear 

wood varnish is 420 g/L, which is 

more stringent than the limits in 

Rule 1106.1 (i.e. 775 g/L for teak 

primer, 550 g/L for clear wood 

sealers, and 490 g/L for clear wood 

varnishes.) 

RACT Equivalent

SCAQMD Rule 1106.1 varies in 

stringency when compared to other 

Districts‟ requirements. For the 

majority of the categories, Rule 

1106.1 is as stringent as or more 

stringent than the other Districts‟

rules.

1107 VOC Coating of Metal Parts and 

Products

(Amended 1/6/06)

Coating-specific emission limits 

from 2.3 lbs/gal – 3.5 lbs/gal. In 

lieu of complying with specific 

emission limits, operator can use 

air pollution control system with 

at least 95% control efficiency

(or 5 ppmv outlet) and 90% 

capture efficiency. Solvent 

cleaning operations must comply 

with Rule 1171.

Ventura Rule 74.12 (Amended 

4/8/08) generally has the same 

coating-specific limits as South 

Coast Rule 1107, except in the 

following categories: 

 Limit for metallic coating is 3 

lbs/gal (3.5 lbs/gal in Rule 

1107);

 Limit for camouflage is 3 lbs/gal 

(3.5 lbs/gal in Rule 1107);

RACT Equivalent

SCAQMD Rule 1107 varies in 

stringency when compared to other 

Districts‟ requirements. For the

majority of the categories, Rule 1107

is as stringent as or more stringent

than the other Districts‟ rules.
Attachment D: Updated RACM/RACT Analysis

D - 27 February 2015

TABLE D-7 (continued)

Evaluation of SCAQMD VOC Rules and Regulations

RULE 

NO.

TYPE RULE TITLE CURRENT RULE 

REQUIREMENTS

OTHER DISTRICTS’ 2000-2014 

RULES, CONTROL 

MEASURES, U.S. EPA CTGS, 

AND OTHER STUDIES

EVALUATION

1107

(Cont.)

VOC  Limit of pretreatment coatings is 

2.3 lbs/gal (3.5 lbs/gal in Rule 

1107)

 Overall minimum control 

efficiency is 90%, higher than 

Rule 1107 requirement at 85%

San Joaquin Valley Rule 4603 

(Amended 9/17/09) have more 

stringent limits than Rule 1107 for 

baked camouflage and baked 

metallic coating at 360 g/L (420 

g/L in Rule 1107)

1108 VOC Cutback Asphalt

(Amended 2/1/85)

0.5% by volume VOC 

evaporated at 500 degrees F.

Ventura Rule 74.28 – Asphalt 

Roofing Operations (Adopted 

5/10/94) has work practice 

requirements for asphalt roofing 

operations. South Coast does not 

have a similar rule. 

Meets RACT

1108.1 VOC Emulsified Asphalt

(Amended 11/4/83)

3% by volume VOC evaporated 

at 500 degrees F

Meets RACT

1110.2 VOC Emissions from Gaseous and 

Liquid Fueled Engines

(Amended 9/7/12)

Rule 1110.2 has NOx, VOC, CO 

limits for all stationary and 

portable engines over 50 brake 

horse power (bhp).

San Joaquin Valley Rule 4702 

(Amended 11/14/13) has NOx, 

VOC, CO and SOx limits for 

engines rated over 25 bhp.

Meets RACT
Attachment D: Updated RACM/RACT Analysis

D - 28 February 2015

TABLE D-7 (continued)

Evaluation of SCAQMD VOC Rules and Regulations

RULE 

NO.

TYPE RULE TITLE CURRENT RULE 

REQUIREMENTS

OTHER DISTRICTS’ 2000-2014 

RULES, CONTROL 

MEASURES, U.S. EPA CTGS, 

AND OTHER STUDIES

EVALUATION

1110.2

(Cont.)

VOC  11 ppmv NOx

 30 ppmv VOC

 250 ppmv CO

Limits for new non-emergency 

engines driving electrical 

generators are:

 0.07 lbs NOx per MW-hr

 0.20 lbs CO per MW-hr

 0.10 lbs VOC per MW-hr 

NOx limits for low usage biogas 

engines:

 36 ppmv, engines ≥ 500 bhp

45 ppmv, engines < 500 bhp

VOC and CO limits for low 

usage biogas engines:

 40 ppmv VOC, landfill gas

 250 ppmv VOC, digester gas

 2000 ppmv CO.

Portable and agricultural engines 

are not subject to the general 

limits listed above.

Many of Rule 1110.2 engines are 

in RECLAIM, and RECLAIM 

will be amended to incorporate 

feasible BARCT.

 250 ppmv VOC (rich-burn) 

and 750 ppmv VOC (lean 

burn), and

 2000 ppmv CO

- Engines used in agricultural 

operations (AO), or fueled with 

waste gas, or limited used, or 

cyclic loaded and field gas 

fueled are subject to higher 

limits than the above

- In general, all compression 

ignited engines must meet EPA 

Tier 4 standards.

Engines between 25 bhp - 50 bhp, 

non agricultural operations (AO), 

must meet federal standards 

40CFR Part 60 Subpart IIII and 

JJJJ.
Attachment D: Updated RACM/RACT Analysis

D - 29 February 2015

TABLE D-7 (continued)

Evaluation of SCAQMD VOC Rules and Regulations

RULE 

NO.

TYPE RULE TITLE CURRENT RULE 

REQUIREMENTS

OTHER DISTRICTS’ 2000-2014 

RULES, CONTROL 

MEASURES, U.S. EPA CTGS, 

AND OTHER STUDIES

EVALUATION

1113 VOC Architectural Coatings

(Amended 9/6/13)

Coating-specific emission limits 

from 50 g/L – 730 g/L. Allow 

averaging, scheduled to be 

phased out on January 1, 2015.

Exempt containers with capacity 

2 fluid oz or less.

Meets RACT

1114 VOC Petroleum Refinery Coking 

Operations

(Adopted 5/3/13)

A delayed coking unit shall 

depressurize each coke drum to 

less than two (2) pounds per 

square inch, gauge (psig) prior 

to venting it to atmosphere

Meets RACT

1115 VOC Motor Vehicle Assembly 

Line Coating Operations

(Amended 5/12/95)

Limits from 1.2 lbs VOC/gal 

coating for electrophoretic 

primer to 15 lbs/gal of applied 

solids for primer, primer surfacer

and topcoat. Cleaning operations 

must comply with Rule 1171.

San Joaquin Valley Rule 4602, 

(Amended 9/17/09) has more 

stringent limits for: 1) Primer at 

0.7 lbs/gal and 2) Primer surface 

and topcoat at 12 lbs/gal 

Rule 1115 is not as stringent as the 

2008 EPA CTGs for a few coating 

processes for facilities emitting > 15 

lbs/day. The two facilities subject to 

Rule 1115 have a small emission 

inventory of about 0.02 tpd. Staff 

will commit to further rule 

evaluation.

1122 VOC Solvent Degreasers

(Amended 5/1/09)

Contain various work practice 

and design requirements.

Meets RACT

1123 VOC Refinery Process 

Turnarounds

(Amended 12/7/90)

Vent to storage areas or gas 

disposal system until pressure in 

the vessel is below 5 psig or 

within 5% above the minimum 

gauge pressure at which the 

vapors can be collected.

San Joaquin Rule 4454 requires 

control (vapor recovery and 

combustion) and depressurization 

to less than 5 psig. San Joaquin 

2007 AQMP control measure 

proposes to further study the 

inventory associated with this 

category.

Meets RACT
Attachment D: Updated RACM/RACT Analysis

D - 30 February 2015

TABLE D-7 (continued)

Evaluation of SCAQMD VOC Rules and Regulations

RULE 

NO.

TYPE RULE TITLE CURRENT RULE 

REQUIREMENTS

OTHER DISTRICTS’ 2000-2014 

RULES, CONTROL 

MEASURES, U.S. EPA CTGS, 

AND OTHER STUDIES

EVALUATION

1124 VOC Aerospace Assembly and 

Component Manufacturing 

Operations

(Amended 9/21/01)

Coating-specific emission limits 

from 160 – 1000 g/L. Specific 

high transfer coating applications 

(e.g. HVLP spray). In lieu of 

complying with specific 

emission limits, operator can use 

air pollution control system with 

at least 95% control efficiency 

(or 50 ppmv outlet) and 90% 

capture efficiency. 

Solvent cleaning operations must 

comply with Rule 1171.

San Joaquin Valley Rule 4605 

(Amended 6/16/11) has the 

following limits that are more 

stringent than those in Rule 1124: 

 Flight Test Coatings = 600 g/L 

(420 g/l for used on missiles and 

single use target craft, 840 g/L 

for other flight test coatings in 

Rule 1124)

 Fastener Sealant = 600 g/L (675 

g/L for fastener sealant and 600 

g/L for other sealants in Rule 

1124)

Sacramento Rule 456 (Amended 

10/23/08) has the following limits 

that are more stringent than those 

in Rule 1124: 

 Conformal Coating = 600 g/L 

(Rule 1124 limit is 750 g/L)

 Fire Resistant Coatings = 600 

g/L. (Rule 1124 limits are 650 

g/L for Commercial; 800 g/L for 

Military)

 High-Temperature Coating = 

420 g/L. (Rule 1124 limit is 850 

g/L)

 Mold Release Coatings = 762 

g/L. (Rule 1124 limit is 780 

g/L)

RACT equivalent

SCAQMD Rule 1124 varies in 

stringency when compared to other 

Districts‟ requirements. For the

majority of the categories, Rule 1124 

is as stringent as or more stringent 

than the other Districts‟ rules.
Attachment D: Updated RACM/RACT Analysis

D - 31 February 2015

TABLE D-7 (continued)

Evaluation of SCAQMD VOC Rules and Regulations

RULE 

NO.

TYPE RULE TITLE CURRENT RULE 

REQUIREMENTS

OTHER DISTRICTS’ 2000-2014 

RULES, CONTROL 

MEASURES, U.S. EPA CTGS, 

AND OTHER STUDIES

EVALUATION

1124

(con‟t)

VOC  Radiation Effect = 600 g/L. 

(Rule 1124 limit is 800 g/L)

 Rain Erosion Resistant Coating 

= 600 g/L in All Other Category. 

(Rule 1124 limit is 800 g/L)

SCAQMD Rule 1124 has more 

detailed breakdown of specialty 

coating categories (primers, 

coating, adhesives, sealants, 

maskants, lubricants, cleaning 

solvents and strippers) than 

Sacramento Rule 456. A total of 

43 sub-categories (27 in Rule 456) 

was listed in Rule 1124, and most 

of them are as stringent as, or more 

stringent than the analogous 

requirements in Rule 456. For 

example, Rule 456‟s VOC limit is 

622 and 160 g/l for Type I and 

Type II chemical milling maskants 

(250 and 160 g/l for SCAQMD) 

and 850 g/l for other maskants 

(varying from 250 to 850 g/l for 

different sub-categories in 

SCAQMD). 

Ventura Rule 74.13 (Amended 

9/11/12) requires 200 g/L VOC 

limit for solvent cleaning or 25 

mmHg vapor pressure allowance. 
Attachment D: Updated RACM/RACT Analysis

D - 32 February 2015

TABLE D-7 (continued)

Evaluation of SCAQMD VOC Rules and Regulations

RULE 

NO.

TYPE RULE TITLE CURRENT RULE 

REQUIREMENTS

OTHER DISTRICTS’ 2000-2014 

RULES, CONTROL 

MEASURES, U.S. EPA CTGS, 

AND OTHER STUDIES

EVALUATION

1125 VOC Metal Container, Closure, 

and Coil Coating Operations

(Amended 3/7/08)

Coating-specific emission limits 

from 0 g/L (for non food cans) –

660 g/L. Specific high transfer 

coating applications (e.g. HVLP 

spray). In lieu of complying 

with specific emission limits, 

operator can use air pollution 

control system with at least 95% 

control efficiency (or 50 ppmv 

outlet) and 90% capture 

efficiency, which is equivalent to 

an overall control efficiency of 

85%. Solvent cleaning 

operations must comply with 

Rule 1171.

The following limit in San Joaquin 

Rule 4604 (Amended 9/20/07) are 

more stringent than those in Rule 

1125: 

 Two-Piece Interior Body Spray

= 420 g/L (440 g/L in Rule 

1125)

 Three-Piece Interior Body Spray

= 360 g/L (510g/L in Rule 

1125)

In addition, SJV Rule 4604 have 

many limits that are not listed in 

Rule 1125 such as 20 g/L for end 

seal compounds and 225 g/L for 

two-piece interior sheet base 

coating and over-vanish.

Sacramento Rule 452 (Amended 

9/25/2008) has the following more 

stringent limits than Rule 1125:

 Two-Piece Interior Body Spray

= 420 g/L (440 g/L in Rule 

1125)

 Three-Piece Interior Body Spray

= 360 g/L (510g/L in Rule 1125)

Meets RACT

SCAQMD Rule 1125 varies in 

stringency when compared to other 

Districts‟ requirements. For the

majority of the categories, Rule 1125

is as stringent as or more stringent 

than the other Districts‟ rules.

Rule 1125 was amended in 2008 to 

increase control efficiency of 

treatment systems to 95%.

1126 VOC Magnet Wire Coating 

Operations

(Amended 1/13/95)

Coating-specific emission limits 

less than 200 g/L, or use control 

equipment to achieve equivalent 

reduction. Solvent cleaning 

operations must comply with 

Rule 1171.

Meets RACT

(EPA determination 2007)
Attachment D: Updated RACM/RACT Analysis

D - 33 February 2015

TABLE D-7 (continued)

Evaluation of SCAQMD VOC Rules and Regulations

RULE 

NO.

TYPE RULE TITLE CURRENT RULE 

REQUIREMENTS

OTHER DISTRICTS’ 2000-2014 

RULES, CONTROL 

MEASURES, U.S. EPA CTGS, 

AND OTHER STUDIES

EVALUATION

1127 VOC Emission Reductions from 

Livestock Waste

(Adopted 8/6/04)

Good housekeeping practices. 

Note: The SCAQMD just 

adopted Rule 223 in June 2006 

to reduce emission for large 

confined animal facilities. Rule 

223 includes series of good 

management practices that are 

more stringent than Rule 1127.

Sacramento Rule 496 – Large 

Confined Animal Facilities 

(Adopted 8/24/06), has more 

stringent control and good 

management practices than South 

Coast Rule 1127 (e.g. venting to 

control system with at least 80% 

control efficiency). 

In the 2007 AQMP, San Joaquin 

Valley proposed to increase the 

number of good management 

practices and control efficiency as 

called for in their existing rule.

Meets RACT

Rule 1127 and 223 together are as

stringent as other Districts‟ rules.

1128 VOC Paper, Fabric and Film 

Coating Operations

(Amended 3/8/96)

Coating-specific emission limits 

from 20 – 265 g/L. Specific high 

transfer coating applications (e.g. 

HVLP spray). Alternatively, 

operator can also use control 

system with at least 95% control 

efficiency (or 50 ppmv outlet) 

and 90% capture efficiency. 

Solvent cleaning operations must 

contain 15% or less VOC or 85% 

VOC must be collected and 

disposed of.

Midwest RPO proposes 100% 

capture and 90% - 95% control 

efficiency for existing sources and 

97% for new/reconstructed 

sources. 

RACT equivalent

District rule is more stringent than 

the 2007 EPA CTG.

The incremental increase from 85% 

to 90%-97% in control efficiency is 

not cost-effective for the existing 

sources in the South Coast air 

basin.(note)

Note: Per communication with Bill 

Milner on February 13, 2007.
Attachment D: Updated RACM/RACT Analysis

D - 34 February 2015

TABLE D-7 (continued)

Evaluation of SCAQMD VOC Rules and Regulations

RULE 

NO.

TYPE RULE TITLE CURRENT RULE 

REQUIREMENTS

OTHER DISTRICTS’ 2000-2014 

RULES, CONTROL 

MEASURES, U.S. EPA CTGS, 

AND OTHER STUDIES

EVALUATION

1130 VOC Graphic Arts

(Amended 5/2/14)

VOC content limits: 16 g/l – 185 

g/l for fountain solution, 150 g/l 

for adhesives, 225 g/l - 300 g/l 

for inks and coatings. In lieu of 

meeting specific emission limits, 

control device with overall 

control efficiency from 90% -

95% can be used to achieve 

equal or better emission 

reductions.

VOC limits for cleaning 

solutions for printing presses are 

in Rule 1171 ranging from 25 g/l 

(0.21 lb/gal) for flexographic 

printing to 100 g/l (0.83 lb/gal) 

for lithographic printing (even 

though 500 g/l is allowed up to 

end of year 2007.)

Rule 1130 was recently amended 

to reduce fountain solution VOC 

content to between 16-85 g/L

with optional control device 

efficiency of 90-95%. The rule 

meets current CTG 

specifications.

The U.S. EPA CTG for 

lithographic and letterpress, 

September 2006, recommends:

 Destruction efficiency of 90% 

to 95% depending on the date 

of installation (or 20 ppmv 

VOC outlet concentration) for 

heat-set web offset presses 

with potential to emit, prior to 

controls, of at least 25 tpy. 

 For all operations emitting 15 

lb/day, requirements for 

fountain solution are:

 1.6% by weight alcohol 

or less as applied, or 3% 

if refrigerated chiller is 

used, or 5% alcohol 

substitute for heat-set 

web presses;

 5% alcohol for sheet-fed 

presses;

 5% alcohol substitute and 

no alcohol in fountain 

solution for cold-set web 

presses.

Meets RACT

SCAQMD Rule 1130 was recently 

amended (05/02/14) and is 

equivalent to CTG requirements.
Attachment D: Updated RACM/RACT Analysis

D - 35 February 2015

TABLE D-7 (continued)

Evaluation of SCAQMD VOC Rules and Regulations

RULE 

NO.

TYPE RULE TITLE CURRENT RULE 

REQUIREMENTS

OTHER DISTRICTS’ 2000-2014 

RULES, CONTROL 

MEASURES, U.S. EPA CTGS, 

AND OTHER STUDIES

EVALUATION

1130 

(Cont.)

Bay Area, Regulation 8, Rule 20 

(Amended 11/19/08) requires 8% 

VOC content in fountain solution. 

In addition, the rule requires 

recordkeeping for digital printing, 

cleaning and stripping of UV or 

electron beam-cured inks for 

further study potential emission 

reductions in a near future.

Ventura Rule 74.19 (Amended 

6/14/11) requires low VOC content 

in fountain solution used in 

lithographic presses.

In addition, the U.S. EPA CTG for 

lithographic and letterpress, 

September 2006, recommends:

 Destruction efficiency of 90% 

to 95% depending on date of 

installation (or 20 ppmv outlet 

concentration) for heat-set web 

with potential to emit, prior to 

controls, of at least 25 tpy. 

 For operations emitting 15 

lb/day, fountain solution must 

be 1) 1.6% alcohol or less, or 
Attachment D: Updated RACM/RACT Analysis

D - 36 February 2015

TABLE D-7 (continued)

Evaluation of SCAQMD VOC Rules and Regulations

RULE 

NO.

TYPE RULE TITLE CURRENT RULE 

REQUIREMENTS

OTHER DISTRICTS’ 2000-2014 

RULES, CONTROL 

MEASURES, U.S. EPA CTGS, 

AND OTHER STUDIES

EVALUATION

1130 

(Cont.)

2) 3% with refrigerated chiller 

or 3) 5% alcohol substitute for 

heat-set web presses; 4) 5% 

alcohol for sheet-fed presses; 5) 

5% alcohol substitute and no 

alcohol in fountain solution for 

cold-set web presses.

The EPA CTG for rotogravure and 

flexographic, adopted in 

September 2006, recommends 

control efficiency of 80% for 

presses installed after March 1995, 

and 65% - 75% for older presses.

1130.1 VOC Screen Printing Operations

(Amended 12/13/96)

VOC content limits ranges from 

400 g/L – 800 g/L for materials 

used in screen printing. In lieu 

of specific emission limits, 

control device can be used to 

achieve equal or better 

reductions, at least 95%.

Bay Area, Regulation 8, Rule 20

(Amended 11/19/08) has more 

stringent limit for adhesives at 150 

g/L (400 g/L in Rule 1130.1).

Sacramento Rule 450 (Amended 

10/23/08) has more stringent limits 

than Rule 1130.1 in the following 

areas: 1) limit for electronic circuit 

ink is 800 g/L (850 g/L in Rule 

1130.1); 2) limit for adhesives is 

150 g/L (400 g/L in Rule 1130.1)

Meets RACT

SCAQMD Rule 1130.1 varies in 

stringency when compared to other 

Districts‟ requirements. For the 

majority of the categories, Rule 

1130.1 is as stringent as or more 

stringent than the other Districts‟

rules.
Attachment D: Updated RACM/RACT Analysis

D - 37 February 2015

TABLE D-7 (continued)

Evaluation of SCAQMD VOC Rules and Regulations

RULE 

NO.

TYPE RULE TITLE CURRENT RULE 

REQUIREMENTS

OTHER DISTRICTS’ 2000-2014 

RULES, CONTROL 

MEASURES, U.S. EPA CTGS, 

AND OTHER STUDIES

EVALUATION

1131 VOC Food Product Manufacturing 

and Processing Operations

(Amended 6/6/03)

VOC content limits from 120 –

200 g/L, or air pollution control 

system with at least 95% control 

efficiency and 90% capture 

efficiency. Solvent cleaning 

operations must contain 15% or 

less VOC or 85% VOC must be 

collected and disposed of.

Meets RACT

1132 VOC Further Control of VOC 

from High Emitting Spray 

Booths

(Amended 5/5/06)

Further reduce emissions by 65% 

from the baseline primarily

through the installation of 

control devices, beyond and 

above the use of coatings that 

comply with existing coating 

rules.

Meets RACT

1133,

1133.1

VOC Rule 1133 - Composting and 

Related Operations –

General Administrative 

Requirements

(Adopted 1/10/03)

Rule 1133.1 – Chipping and 

Grinding Activities

(Amended 7/8/11)

Various performance standards. 

Air pollution control must have 

80% control efficiency or 

greater. Existing operations 

must reduce up to 70% baseline 

VOC and ammonia emissions. 

Baseline emission factors are 

1.78 lbs VOC/ton throughput and 

2.93 lbs NH3/ton throughput.

Meets RACT
Attachment D: Updated RACM/RACT Analysis

D - 38 February 2015

TABLE D-7 (continued)

Evaluation of SCAQMD VOC Rules and Regulations

RULE 

NO.

TYPE RULE TITLE CURRENT RULE 

REQUIREMENTS

OTHER DISTRICTS’ 2000-2014 

RULES, CONTROL

MEASURES, U.S. EPA CTGS, 

AND OTHER STUDIES

EVALUATION

1136 VOC Wood Products Coatings

(Amended 6/14/96)

VOC content limits range from 

2.3 – 6.3 lbs/gal VOC. 

Averaging provisions and add-on 

control are allowed. Transfer 

efficiency is at least 65%, or 

operator must use certain type of 

equipment (e.g. HVLP). Solvent 

cleaning operations must comply 

with Rule 1171.

Ventura Rule 74.30 (Amended 

6/27/06) has more stringent limit 

for high-solid stains on new wood 

products at 2 lbs/gal (2.9 lbs/gal in 

Rule 1136). In lieu of coating 

specific limits, control equipment 

achieving 90% efficiency is 

required. No averaging provisions 

in Ventura. Rule 74.30 has higher 

emissions limits for refinishing 

operations.

San Joaquin Valley Rule 4606 

(Amended 10/16/08) is more 

stringent in the following areas:

 Rule 1136 allows the use of a 

stripper with limits higher than 

350 g/L if the stripper has low 

vapor pressure of 2 mmHg. SJV 

does not have this allowance;

SJV Rule 4606 requires a min 

overall control efficiency of 85% -

90% for flat wood paneling 

products, whereas Rule 1136 does 

not have control efficiency 

requirement.Rule 4606 exempts 

refinishing, replacement, and 

custom Replica Furniture 

Operations. 

SCAQMD Rule 1136 also has a 

VOC limit of 120 g/L for lowstain barrier coat. This category is 

RACT Equivalent

SCAQMD Rule 1136 varies in 

stringency when compared to other 

Districts‟ requirements. For the 

majority of the categories, Rule 1136 

is as stringent as or more stringent 

than the other Districts‟ rules.
Attachment D: Updated RACM/RACT Analysis

D - 39 February 2015

TABLE D-7 (continued)

Evaluation of SCAQMD VOC Rules and Regulations

RULE 

NO.

TYPE RULE TITLE CURRENT RULE 

REQUIREMENTS

OTHER DISTRICTS’ 2000-2014 

RULES, CONTROL 

MEASURES, U.S. EPA CTGS, 

AND OTHER STUDIES

EVALUATION

1136

(con‟t)

VOC not found in SJV/Ventura and it is 

lower than their general limits.

Bay Area, Regulation 8, Rule 32, 

(Amended 8/5/09) has lower limits 

for surface preparation and 

cleanup, including stripping, at 

0.21 lbs/gal. Solvent cleaning 

operations and the storage and 

disposal of VOC containing 

materials are subject to Rule 1171 

(general limit = 0.21 lbs/gal) in 

SCAQMD. Bay Area has higher

emission limit of clear topcoat (4.6 

lbs /gal vs. 2.3 lbs/gal in 

SCAQMD) for custom furniture 

Bay Area exempts refinishing, 

replacement, and custom Replica 

Furniture Operations.

1141 VOC Control of Volatile Organic 

Compound Emissions from 

Resin Manufacturing

(Amended 11/17/00)

95% - 98% control or 0.12 – 0.5 

lbs/1000 lbs of resin produced

Meets RACT
Attachment D: Updated RACM/RACT Analysis

D - 40 February 2015

TABLE D-7 (continued)

Evaluation of SCAQMD VOC Rules and Regulations

RULE 

NO.

TYPE RULE TITLE CURRENT RULE 

REQUIREMENTS

OTHER DISTRICTS’ 2000-2014 

RULES, CONTROL 

MEASURES, U.S. EPA CTGS, 

AND OTHER STUDIES

EVALUATION

1141.1 VOC Coatings and Ink 

Manufacturing

(Amended 11/17/00)

Operational work practices Meets RACT

1142 VOC Marine Tank Vessel 

Operations

(Amended 7/19/91)

2 lbs/1000 barrels liquid loaded 

or 95% emissions reduced

Meets RACT

1141.2 VOC Surfactant Manufacturing

(Amended 1/11/02)

95% control or 0.5 lbs/1000 lbs 

of surfactant produced

Meets RACT

1143 VOC Consumer Paint Thinners 

and Multi-purpose Solvents

(Amended 12/3/10)

Set VOC content of 25 g/l for 

consumer paint thinner and 

multi-purpose solvent beginning 

1/1/2011

Meets RACT

1144 VOC Metalworking Fluids and 

Direct-contact Lubricants

(Amended 7/9/10)

Various limits from 50 g/L – 340 

g/L. Add-on control at 90% 

capture efficiency, 95% control 

efficiency (or 5 ppmv outlet)

Meets RACT

1145 VOC Plastic, Rubber, Leather and 

Glass Coatings

(Amended 12/4/2009)

VOC limits: 50–800 lbs VOC 

per gallon. Avg provisions and 

add-on control at 95% control 

efficiency (50 ppmv outlet), 90% 

capture efficiency. High transfer 

coating equipment (e.g. HVLP). 

Solvent cleaning operations must 

comply with Rule 1171.

Meets RACT
Attachment D: Updated RACM/RACT Analysis

D - 41 February 2015

TABLE D-7 (continued)

Evaluation of SCAQMD VOC Rules and Regulations

RULE 

NO.

TYPE RULE TITLE CURRENT RULE 

REQUIREMENTS

OTHER DISTRICTS’ 2000-2014 

RULES, CONTROL 

MEASURES, U.S. EPA CTGS, 

AND OTHER STUDIES

EVALUATION

1145

(Cont.)

VOC limits: 50–800 lbs VOC 

per gallon. Avg provisions and 

add-on control at 95% control 

efficiency (50 ppmv outlet), 90% 

capture efficiency. High transfer 

coating equipment (e.g. HVLP). 

Solvent cleaning operations must 

comply with Rule 1171.

1148 VOC Thermally Enhanced Oil 

Recovery Wells

(Amended 11/5/82)

4.5 lbs/day or less per well Meets RACT

1148.1 VOC Oil and Gas Production 

Wells

(Amended 3/5/04)

 Set limits for total TOC 

of 500 ppm in well 

cellar;

 Requires well head 

liquid capture;

 limits the storage of 

organic liquids in the 

well cellar but 

conditionally allows 

TOC emissions with 

control equipment less 

than 250 ppm for safety 

considerations

 sets requirement for 

operations at the well 

head.

 Requires 95% control 

equipment efficiency for 

natural gas vented to 

atmosphere 

Glycol dehydrators in gas and oil 

production regulated by 

VCAPCD‟s Rule 71.5 are jointly 

regulated by SCAQMD Rules 

1148.1 and Rule 1173 (Control of 

Volatile Organic Compound Leaks 

and Releases from Components at 

Petroleum Facilities and Chemical 

Plants) which meet RACT

Rule currently being evaluated for 

amendments for further VOC 

reduction.

.
Attachment D: Updated RACM/RACT Analysis

D - 42 February 2015

TABLE D-7 (continued)

Evaluation of SCAQMD VOC Rules and Regulations

RULE 

NO.

TYPE RULE TITLE CURRENT RULE 

REQUIREMENTS

OTHER DISTRICTS’ 2000-2014 

RULES, CONTROL 

MEASURES, U.S. EPA CTGS, 

AND OTHER STUDIES

EVALUATION

1149 VOC Storage Tank Degassing

(Amended 5/2/08)

Degassing operations must be 

controlled such that the VOC 

concentration within the tank is 

reduced to less than 5,000 ppmv 

for a minimum time limit 

estimated in the rule based on 

volume of the gas to be freed in 

the tank and the flow rate 

through control device.

Ventura Rule 74.26, 74.27 

(Adopted 10/12/04) requires 

degassing of crude oil, gasoline 

and other high TVP liquid storage 

tanks be controlled by vapor 

recovery or flare having 95% 

control efficiency until the vapor 

concentration in the tanks is less 

than 10,000 ppmv.

Bay Area Rule 8-10 (Adopted 

1/21/04) sets requirements for 

depressurizing process vessels at 

petroleum refineries and chemical 

plants. The gases must be vented 

to control devices until the vapor 

concentration in the tanks is less 

than 10,000 ppmv.

Rule development is in progress at 

San Joaquin to eliminate 

exemptions and require more 

stringent VOC control.

RACT Equivalent

1150.1 VOC Control of Gaseous 

Emissions from Active 

Landfills

(Amended 4/1/11)

98% control or 20 ppmv non 

methane organic compounds. 

50-500 ppmv total organic 

compounds above background

Meets RACT
Attachment D: Updated RACM/RACT Analysis

D - 43 February 2015

TABLE D-7 (continued)

Evaluation of SCAQMD VOC Rules and Regulations

RULE 

NO.

TYPE RULE TITLE CURRENT RULE 

REQUIREMENTS

OTHER DISTRICTS’ 2000-2014 

RULES, CONTROL 

MEASURES, U.S. EPA CTGS, 

AND OTHER STUDIES

EVALUATION

1151 VOC Motor Vehicle and Mobile 

Equipment Non-Assembly 

Line Coating Operations 

(Amended 9/5/14)

VOC content limits range from 

250 – 840 grams VOC per liter. 

Averaging provisions are 

allowed. High transfer coating 

equipment (e.g. HVLP) is 

required. Solvent cleaning 

operations must comply with 

Rule 1171.

San Joaquin Valley Rule 4602 

(Amended 9/17/09) is more 

stringent in the following areas: 1) 

adhesive at 250 g/L (540 g/L in 

Rule 1151) and 2) truck bed liner 

coating at 200 g/L (310 g/L in Rule 

1151)

Sacramento Rule 459 (Amended 

8/25/11) is more stringent in the 

following areas: 1) multi-color 

coating at 520 g/L for mobile 

equipment driven on rails (680 g/L 

in Rule 1151), 2) truck bed liner 

coating at 200 g/L (310 g/L in Rule 

1151)

Bay Area, Regulation 8, Rule 45 

(Amended 12/3/08) is more 

stringent in the following areas: 1) 

VOC limit for surface preparation 

and cleanup, including stripping, of 

0.2 lbs/gal or 2) a minimum 85% 

overall control efficiency.

RACT Equivalent

SCAQMD Rule 1151 varies in 

stringency when compared to other 

Districts‟ requirements. For the 

majority of the categories, Rule 1151 

is as stringent as or more stringent 

than other Districts‟ rules.

1153 VOC Commercial Bakery Ovens

(Adopted 1/13/95)

Emission reduction of 70% or 

more is required for existing 

ovens emitting between 50 lbs –

100 lbs VOC/day, 95% or more 

for ovens emitting more than 100 

lbs/day, and 95% or more for 

new ovens.

Meets RACT
Attachment D: Updated RACM/RACT Analysis

D - 44 February 2015

TABLE D-7 (continued)

Evaluation of SCAQMD VOC Rules and Regulations

RULE 

NO.

TYPE RULE TITLE CURRENT RULE 

REQUIREMENTS

OTHER DISTRICTS’ 2000-2014 

RULES, CONTROL 

MEASURES, U.S. EPA CTGS, 

AND OTHER STUDIES

EVALUATION

1162 VOC Polyester Resin Operations

(Amended 7/8/05)

VOC limits (monomer content) 

from 10-48% by weight or 

alternatively 90% control 

efficiency for add-on control

Regulation 8, Rule 50 (Amended 

12/2/09) is similar to Rule 1162, 

except the limit for corrosion 

resistant resin is more stringent at 

40% - 46% (48% in Rule 1162). 

The rule allows some usage of 

acetone

RACT Equivalent

1164 VOC Semiconductor 

Manufacturing

(Amended 1/13/95)

VOC limit for cleanup solvents 

is 200 g/L or low vapor pressure 

of 0.64 psia at 68 degree F. 

Photoresist applications must be 

vented to control.

Meets RACT

1166 VOC Volatile Organic Compound 

Emissions from 

Decontamination of Soil

(Amended 5/11/01)

Good management practices. Ventura Rule 74.29 – Soil 

Decontamination Operations 

(Amended 4/8/08) has standards 

for soil decontamination (e.g. 50 -

100 ppmv ). Leaking agricultural 

tanks is exempted.

Bay Area Rule 8-40 (Amended 

6/15/05) for soil decontamination

and tank degassing. All vapor 

exceeding the specified limit based 

on organic content and aeration 

rate must be vented to control 

devices with ≥ 90% efficiency 

until meeting 5,000 ppmv.

San Joaquin Valley Rule 4651 

(Amended 9/20/07) employs good 

management practices similar to 

those in SCAQMD. For ex-situ 

decontamination, VOC emissions 

must be vented to control devices 

with 95% efficiency or more. 

RACT Equivalent

There is no federal policy or 

guidance describing RACT for this 

source category

Rule 1166 is included in the 2007 

RACT/RACM demonstration that 

was approved by USEPA in 2011.
Attachment D: Updated RACM/RACT Analysis

D - 45 February 2015

TABLE D-7 (continued)

Evaluation of SCAQMD VOC Rules and Regulations

RULE 

NO.

TYPE RULE TITLE CURRENT RULE 

REQUIREMENTS

OTHER DISTRICTS’ 2000-2014 

RULES, CONTROL 

MEASURES, U.S. EPA CTGS, 

AND OTHER STUDIES

EVALUATION

1168 VOC Adhesive and Sealant 

Applications

(Amended 1/7/05)

VOC limits for solvents range 

from 30 – 775 lbs VOC per 

gallon. Require the use of high 

transfer efficiency equipment 

(e.g. HVLP spray). In lieu of 

meeting the VOC limits, using 

add-on control with 80% control 

efficiency is allowed.

San Joaquin Valley Rule 4653 

(Amended 9/16/10) has more 

stringent limits in the following 

areas:

 100 g/L for Cellulosic Plastic 

Welding Adhesive, 100 g/L for 

Styrene Acrylonitrile Welding 

Adhesive, and 200 g/L for 

Reinforced Plastic Composite 

Adhesive (Rule 1168 limit is 

250 g/L limits for all three 

categories)

 Minimum overall control 

efficiency is 85% (80% in Rule 

1168)

Staff has completed its evaluation 

and is proposing to reduce primer 

VOC limits to 250 g/L to meet the 

CTG. 

1171 VOC Solvent Cleaning Operations

(Amended 5/1/09)

VOC limits for solvents are 25 

g/L in general, and have a 100-

800 g/L VOC for specific 

cleaning operations. In lieu of 

meeting the VOC limits, add-on 

control having 90% collection 

efficiency and 95% destruction 

efficiency or meeting 50 ppmv 

outlet concentration can be used. 

The U.S. EPA RACT published in 

September 2006 limit is 50 g/L or 

an overall control efficiency of 

85%. The U.S. EPA is not 

recommending limits beyond 50 

g/L; but also recommends states to 

adopt higher limits based on 

individual performance 

requirements of specific 

applications. 

Meets RACT
Attachment D: Updated RACM/RACT Analysis

D - 46 February 2015

TABLE D-7 (continued)

Evaluation of SCAQMD VOC Rules and Regulations

RULE 

NO.

TYPE RULE TITLE CURRENT RULE 

REQUIREMENTS

OTHER DISTRICTS’ 2000-2014 

RULES, CONTROL 

MEASURES, U.S. EPA CTGS, 

AND OTHER STUDIES

EVALUATION

1173 VOC Fugitive Emissions of 

Volatile Organic Compounds

(Amended 2/6/09)

 Require to connect 

atmospheric PRDs to vapor 

recovery or add-on control

by first turnaround, if the 

facility experiences:

 a second release of more 

than 500 lbs VOC within 

any five year period, or

 any release of 2,000 lbs 

VOC in any 24 hour 

period.

In lieu of connecting PRDs to 

control, operator may elect to 

pay mitigation fee of 

$350,000 for any release 

exceeding the threshold.

 Leak Detection and Repair 

(LDAR) program to reduce 

fugitive emissions. Leak 

thresholds are:

 for light liquid/gas/vapor 

service >10,000 ppmv,

 for PRDs >200 ppmv, 

 for pumps in heavy 

liquid >100 ppmv

Bay Area Rule 8-28 (amended 

12/21/05) requires atmospheric 

PRDs to be:

 vented to vapor recovery or 

equivalent control devices 

that have 95% control 

efficiency within one year of 

the second release event of 

greater than 10 lbs VOC.

 equipped with at least two or 

three redundant preventive 

measures to minimize 

episodic releases, and

 equipped with tell-tale 

indicators.

North Central Texas – Final 2007 

SIP, Oil & Gas Production, Natural 

Gas Processing, Measure #144. 

Propose to revise leak definitions 

and requirements for shorter repair 

periods based on recently revised 

San Joaquin Valley Rule 4409, 

amended July 2004.

Meets RACT
Attachment D: Updated RACM/RACT Analysis

D - 47 February 2015

TABLE D-7 (continued)

Evaluation of SCAQMD VOC Rules and Regulations

RULE 

NO.

TYPE RULE TITLE CURRENT RULE 

REQUIREMENTS

OTHER DISTRICTS’ 2000-2014 

RULES, CONTROL 

MEASURES, U.S. EPA CTGS, 

AND OTHER STUDIES

EVALUATION

1174 VOC Control of Volatile Organic 

Compound Emissions from 

the Ignition of Barbecue 

Charcoal

(Amended 10/5/90)

VOC emissions less than 0.02 lb 

VOC per start.

Meets RACT

1175 VOC Control of Emissions from 

the Manufacture of 

Polymeric Cellular (Foam) 

Products

(Amended 11/5/10)

VOC limit for expandable 

polystyrene molding operations 

is less than 2.4 lbs/100 lbs of raw 

material processed

Meets RACT

1176 VOC Sumps and Wastewater 

Separators

(Amended 9/13/96)

 Wastewater: 500 ppmv

 Sumps and wastewater 

separators must have floating 

cover with seals; or fixed 

cover vented to control

 Sewer lines: totally enclosed

 Process drains: with 

SCAQMD approved water 

seals

 Junction boxes: totally 

enclosed

 Control device:  95% 

efficiency or 500 ppmv 

leak above background

 Monthly to annually 

inspection

Bay Area Rule 8-8 (Amended 

9/15/04) in general is similar to 

South Coast Rule 1176, with the 

following exceptions:

 Floating covers must have 

double seals; and

 Semi-annual inspection is 

allowed.

In their 2007 AQMP, San Joaquin 

Valley proposes to further study 

the following areas:

 Require crude oil production 

sumps to have fixed roof and 

vented to control with 99% 

control efficiency; 

 Require wastewater separators 

to have fixed roof and vented 

to control with 95% control 

efficiency, and

 Require floating roofs to be 

equipped with double seals

Meets RACT
Attachment D: Updated RACM/RACT Analysis

D - 48 February 2015

TABLE D-7 (concluded)

Evaluation of SCAQMD VOC Rules and Regulations

RULE 

NO.

TYPE RULE TITLE CURRENT RULE 

REQUIREMENTS

OTHER DISTRICTS’ 2000-2014 

RULES, CONTROL 

MEASURES, U.S. EPA CTGS, 

AND OTHER STUDIES

EVALUATION

1177 VOC Liquefied Petroleum Gas 

Transfer and Dispensing

(Adopted 6/1/12)

The rule specifies tightened 

connectors (valves and seals) for 

vapor and liquid transfer from 

storage tanks to cargo tanks to 

minimize leakage.

Meets RACT

1178 VOC Further Reductions of VOC 

Emissions From Storage 

Tanks at Petroleum Facilities

(Amended 4/7/06)

Applicable to high emitting 

facility that has 20 tpy VOC 

emissions or more and tanks 

>19,815 gals with liquids having 

TVP > 0.1 psia. Rule 1178 

requires doming for high 

emitting external floating roof 

tanks, better seals and better 

control for all tanks.

(Note that Rule 463 is applicable 

for tanks >19,815 gals at all 

facilities and have requirements 

for fixed roof tanks and floating 

roof tanks.)

In the 2007 AQMP, San Joaquin 

proposes to revise Rule 4623 to 

lower tank capacity applicability, 

lower TVP threshold, and revisit 

exemptions to broaden source 

applicability.

Midwest RPO control measure 

proposes to expand source 

applicability of LADCO state rules 

to include 10,000 gal tanks.

Meets RACT

1179 VOC Publicly Owned Treatment 

Works Operations

(Amended 3/6/92)

Include recordkeeping 

requirements.

Meets RACT

1183 VOC Outer Continental Shelf

(OCS) Air Regulations

(Adopted 3/12/93)

Adopt by reference Code of 

Federal, Part 55, Title 40.

Meets RACT

1189 VOC Emissions From Hydrogen 

Plant Process Vents

(Adopted 1/21/00)

For existing plants, 2.5 lbs VOC 

per million cubic feet of 

hydrogen produced. For new 

plants, 0.5 lbs VOC per million 

cubic feet of hydrogen produced.

Meets RACT
Attachment D: Updated RACM/RACT Analysis

D - 49 February 2015

TABLE D-8

Evaluation of SCAQMD Ammonia (NH3) Rules and Regulations

RULE 

NO.

TYPE RULE TITLE CURRENT RULE 

REQUIREMENTS

OTHER DISTRICTS’ 2000-2014 

RULES, CONTROL 

MEASURES, U.S. EPA CTGS, 

AND OTHER STUDIES

EVALUATION

223 NH3 Emissions Reduction Permits 

From Large Confined 

Animal Facilities

(Adopted 6/2/06)

Sets permit requirement for new 

and modified LCAF facilities.

Specifics mitigation options by 

animal and facility type for:

 Feed and silage 

handling,

 Milk parlor operations,

 Corrals and free stall 

barn operations,

 Handling of manure and 

solids,

 Handling of manure in 

liquid form

 Land application of 

liquid or solid manure

SJVAPCD Rule 4570 sets 

comparable permit requirements 

and mitigation measures.

Rule 223 meets RACT through its 

implementation of technically 

feasible mitigation measures. The 

focus of the SJVAPCD rule is not 

applicable in the Basin for dry feed 

operations.

1105.1 NH3 Reduction of PM10 and 

Ammonia Emissions From 

Fluid Catalytic Cracking 

Units

(Adopted 11/7/03)

0.005 grain/dscf PM10 and 10 

ppmv NH3 slip

RACT Equivalent

1127 NH3 Emission Reductions from 

Livestock Waste

(Adopted 8/6/04)

Set protocol for dairy farm 

manure removal and processing 

and sets alternate planning 

requirements for manure 

composting

SJVAPCD Rule 4565 and 4566 

sets comparable permit 

requirements and mitigation 

measures.

RACT Equivalent
Attachment D: Updated RACM/RACT Analysis

D - 50 February 2015

TABLE D-8 (continued)

Evaluation of SCAQMD Ammonia (NH3) Rules and Regulations

RULE 

NO.

TYPE RULE TITLE CURRENT RULE 

REQUIREMENTS

OTHER DISTRICTS’ 2000-2014 

RULES, CONTROL 

MEASURES, U.S. EPA CTGS, 

AND OTHER STUDIES

EVALUATION

1133.2 NH3 Emission Reductions from 

Co-Composting Operations

(Adopted 1/10/03)

Various performance standards. 

Air pollution control must have 

80% control efficiency or 

greater. Existing operations 

must reduce up to 70% baseline 

VOC and ammonia emissions. 

Baseline emission factors are 

1.78 lbs VOC/ton throughput and 

2.93 lbs NH3/ton throughput.

San Joaquin Rule 4565 –

Biosolids, Animal Manure, and 

Poultry Litter Operations (Adopted 

3/15/07) and Rule 4566 – Organic 

Material Composting Operations 

(Adopted 8/18/11) have various 

operational requirements for these 

operations as well as the operators 

who landfills, composts, or cocomposts these materials. The 

applicability of Rules 4565/4566 is 

broader than the applicability of 

Rule 1133.3. In addition, Rules 

4565/4566 include additional 

mitigation measures to control 

VOC from composting active piles 

(e.g. maintain minimum oxygen 

concentration of 5%, moisture 

content of 40%-70%, carbon to 

nitrogen ratio of 20-1). San 

Joaquin‟s rule does not address 

chipping & grinding as in Rule 

1133.1. 

RACT Equivalent

SCAQMD Rule 1133.2 is more 

stringent than San Joaquin‟s Rule 

4565 for larger co-composting 

facilities and less stringent for 

smaller co-composting facilities. 

While SCAQMD Rule 1133.2 

requires either 70 or 80% overall 

emission reductions from all parts of 

composting process, San Joaquin‟s 

Rule 4565 requires add-on controls 

to apply only to the active 

composting phase. Rule 1133.2 also 

has more stringent requirements for 

in-vessel composting.
Attachment D: Updated RACM/RACT Analysis

D - 51 February 2015

TABLE D-8 (concluded)

Evaluation of SCAQMD Ammonia (NH3) Rules and Regulations

RULE 

NO.

TYPE RULE TITLE CURRENT RULE 

REQUIREMENTS

OTHER DISTRICTS’ 2000-2014 

RULES, CONTROL 

MEASURES, U.S. EPA CTGS, 

AND OTHER STUDIES

EVALUATION

1133.3 NH3 Emission Reductions from 

Greenwaste Composting 

Operations 

(Adopted 7/8/11)

Include requirements for 

composting greenwaste, or 

greenwaste in combination of 

manure or foodwaste. Include 

various performance standards. 

Require air pollution control 

with efficiency of 80% or greater

for operations greater than 5000 

tons/year of foodwaste. 

For operations less than 5000 

tons/year, require the composting 

piles to be covered, watered, and 

turned, or operated with 

measures that reduce at least 

40% VOC emission and 20% 

NH3 emissions. 

RACT Equivalent
A T T A C H M E N T E

C L E A N A I R A C T, S U B P A R T 4, S E C T I O N 1 8 9 ( E ) 

A N D O T H E R P R E C U R S O R R E Q U I R E M E N T S
Attachment E: CAA, Subpart 4, Section 189(e) And Other Precursor Requirements

E -1 February 2015

BACKGROUND

PM2.5 has four major precursors, other than direct PM2.5 emissions, that may contribute to the 

development of the ambient PM2.5: ammonia, NOx, SOx, and VOC. The 2012 AQMP 

modeling analysis resulted in a set of ratios that reflect the relative amounts of ambient PM2.5 

improvements expected from reductions of PM2.5 precursors emissions. For instance, Table 5-2 

in Chapter 5 of the 2012 AQMP demonstrates that one ton of VOC emission reductions is only 

30 percent as effective as one ton of NOx for lowering 24-hour PM2.5 concentrations. VOC 

reductions are only four percent and two percent as effective as SOx and direct PM2.5 

reductions, respectively, on a per ton basis. Thus, VOC controls have a much less significant 

impact on ambient 24-hour PM2.5 levels relative to other PM2.5 precursors.

EMISSIONS CONTRIBUTION

While similar relative contributions to PM2.5 have not been developed for ammonia, the mass 

contributions of ammonium sulfate and ammonium nitrate are accounted for in the SOx and NOx 

contributions. This essentially assumes that PM2.5 formation in the basin is not ammonia 

limited with sufficient ammonia in the atmosphere to combine with available nitrates and 

sulfates. Under these conditions, ammonia controls are much less effective at reducing ambient 

PM2.5 levels than other precursors. 

While the 2012 AQMP ammonia emissions inventory was close to 100 ton per day (TPD), the 

inventory was highly variable in terms of source contributions and spatial distribution throughout 

the Basin. As presented in Table E-1, major sources accounted for 1.7 TPD or less than 2 

percent of the Basin inventory. Furthermore, only four major source emitters were noted in the 

inventory with the single highest major source accounting for less than 0.50 TPD direct 

emissions. All four major sources are located in the western Basin.

TABLE E-1

VOC and Ammonia Emissions Contributions

POLLUTANT ALL SOURCES 

(Tons Per Day)

MAJOR SOURCES

(Tons Per Day)

RELATIVE 

CONTRIBUTION

VOC 45118.021.8%

Ammonia 9931.721.7%

 

1

2012 AQMP - Appendix III: Base and Future Year Emission Inventory; 2014 Annual Average Emissions by Source 

Category in South Coast Air Basin

2

2013 SCAQMD Annual Emission Reporting

3

ARB Almanac 2013 – Appendix B: County Level Emissions and Air Quality by Air Basin; County Emission Trends 
Attachment E: CAA, Subpart 4, Section 189(e) And Other Precursor Requirements

E -2 February 2015

Prior to the 2003 AQMP, significant effort was undertaken to develop inter-pollutant trading 

ratios to meet NSR emissions reduction goals. The primary mechanism was to reduce SOx to 

offset PM emissions. Aerosol chemical mechanisms embedded in box and regional modeling 

platforms where used to estimate the formation rates of ammonium sulfate from local sulfur 

emissions to establish a SOx emissions to PM formation ratio. The analyses determined that the 

influence of ammonia emissions was spatially varying where coastal-metro zone (west Basin) 

trading ratios of SOX to PM valued more than 5:1 per unit SOx emissions to PM. Conversely, 

eastern Basin ratios valued 1:1 since ammonia emissions were abundant and all SOx emissions 

were likely to rapidly transform to particulate ammonium sulfate. The inter-pollutant trades 

made during this time were reviewed by U.S. EPA and were included by reference to the EPA 

sponsored Inter-Pollutant Trading Working Group4.

As part of the controls strategy evaluation for future PM2.5 attainment, additional set of analyses 

were conducted to test the potential impact of the use of SCR as a NOx control mechanism for 

mobile sources in the Basin. The analyses assumed that light as well as heavy duty diesels 

would use the control equipment potentially resulting in a 78-85 percent increase in ammonia 

from those source categories. The results of the analysis, presented at the September 24, 2010 

SCAQMD Mobile Source Committee Meeting5, indicated that a 10 TPD increase in ammonia 

would result in a net 0.22 μg/m3increase in regional PM2.5 concentrations. The emissions 

mostly followed heavy traffic corridors including freeways and major arterials. Regardless, the 

minimal PM2.5 simulated increase from a 10 percent increase in the Basin inventory reflected 

the degree of saturation of ammonia in the Basin and minimal sensitivity of changes in ammonia 

emissions to PM2.5 production.

During the development of the 2012 AQMP, a sensitivity analysis was conducted to test the 

potential impact of using a feed supplement applied to dairy cows on a forecasted basis that 

would reduce bovine ammonia emissions by 50 percent. The analysis focused on the Mira Loma 

area where more than 70 percent of the Basin’s dairy emissions originate. In the sensitivity 

analysis a total of 2.9 TPD emissions were reduced from 103 dairy sources, or an average of 

0.028 TPD per source (roughly one tenth of major source threshold)6. Since the Mira Loma 

monitoring station was embedded among the dairy sources, the reduction of the ground level 

emissions resulted in an approximate 0.16 μg/m3reduction in PM2.5. As in the aforementioned 

analyses, the reduction in regional ammonia emissions resulted in a minimal PM2.5 impact per 

ton emissions reduced.

 

and Forecasts 2012 Emissions. NOTE: 2012 AQMP – Appendix III provides 2014 Annual Average of 102 tpd of NH3; the 

relative contribution would not change (1.7/102 = 1.7%)

4

“Preliminary Assessment of Methods for Determining Interpollutant Offsets”, Correspondence with Scott Bohning U.S. EPA 

Region IX, May 6, 2002.

5

“Impact of Higher On- and Off-road Ammonia Emissions on Regional PM2.5,” Item 3, SCAQMD, Mobile Source Committee, 

September 24, 2010.

6

“2008 24-hour PM2.5 Model Performance/Preliminary Attainment Demonstration,” Item #2, Scientific Technical Modeling 

Peer Group Advisory Committee, June 14, 2012.
Attachment E: CAA, Subpart 4, Section 189(e) And Other Precursor Requirements

E -3 February 2015

Thus, ammonia controls also have a much less significant impact on 24-hour PM2.5 exceedances 

than other precursors. Note however, that the effect on annual PM2.5 levels will be further 

evaluated in the 2016 AQMP.

SECTION 189(E)

Clean Air Act (CAA), Title I, Part D, Subpart 4, Section 189(e) states that control requirements 

applicable to plans in effect for major stationary PM sources shall also apply to major stationary 

sources of PM precursors, except where such sources does not contribute significantly to PM 

levels which exceed the standard in the area. According to the U.S. EPA, a major source in a 

nonattainment area is a source with emission of any one air pollutant greater than or equal to the 

major source thresholds in a nonattainment area. This threshold is generally 100 tons per year 

(tpy) or lower depending on the nonattainment severity for all sources. Emissions are based on 

“potential to emit” and include the effect of add-on emission control technology, if enforceable 

(must be able to show continual compliance with the limitation or requirement). 

Major stationary sources of NOx and SOx are already subject to emission offsets (e.g., 

Regulation XX (RECLAIM) and Regulation XII (New Source Review)). Thus, to demonstrate 

compliance with CAA Subpart 4, Section 189(e), an analysis was conducted of the emissions of

VOC and ammonia from major stationary sources during rule development of amended Rule 

1325 (Federal PM2.5 New Source Review Program) approved by the SCAQMD Governing 

Board on December 5, 2014 (http://www.aqmd.gov/docs/default-source/Agendas/GoverningBoard/2014/2014-dec5-038.pdf?sfvrsn=2). That analysis concluded that VOC and ammonia 

from major sources (emitting 100 tpy or greater) contribute less than 2% of the overall Basinwide VOC and ammonia emissions (Table E-1), and by extension, do not contribute significantly 

to PM levels. Furthermore, both VOC and ammonia are subject to requirements for Best 

Available Control Technology (BACT) under existing New Source Review (NSR) at a zero 

threshold, so those emission will still be minimized. This analysis was also included in the final 

approved staff report for PAR 1325.

NEW SOURCE REVIEW

Because ammonia from major stationary sources does not significantly contribute to PM levels

(see Table E-1), ammonia emission sources have not historically been subject to NSR offset 

requirements. However, for permitted ammonia sources, SCAQMD Rule 1303 (NSR 

Requirements) requires denial of “the Permit to Construct for any relocation, or for any new or 

modified source which results in an emission increase of any nonattainment air contaminant, any 

ozone depleting compound, or ammonia, unless BACT is employed for the new or relocated 

source or for the actual modification to an existing source.” No new major stationary source of 

ammonia is expected to be introduced to the region given that these new sources would be 
Attachment E: CAA, Subpart 4, Section 189(e) And Other Precursor Requirements

E -4 February 2015

subject to BACT requirements (under SCAQMD Rule 1303 (NSR Requirements), BACT shall be

at least as stringent as Lowest Achievable Emissions Rate (LAER) as defined in the federal 

Clean Air Act Section 171(3) [42 U.S.C. Section 7501(3)]). As mentioned above, there are 

currently only four major sources of ammonia (emitting more than 100 tons per year) in the 

South Coast Air Basin. If these sources were new to the region, they would be subject to BACT 

as stringent as LAER and not expected to reach 100 tons per year so as to be classified as a major 

source, thus not subject to NSR offset requirements.

However unlikely, even if new or modified major sources of ammonia increase ammonia 

emissions in the Basin, the ammonia contribution from major sources in the South Coast Air 

Basin will still not be a significant contributor to PM2.5 levels given that all current major 

sources of ammonia account for less than two percent of the overall ammonia emissions 

inventory. For instance, in the extremely unlikely event that ammonia emissions from major 

sources double, they would still contribute less than five percent of the overall ammonia 

inventory.
A T T A C H M E N T F

U P D A T E D L I S T O F C O N T R O L S T R A T E G Y

C O M M I T M E N T S
Attachment F: Updated List of Control Strategy Commitments

F -1 February 2015

UPDATE OF COMMITMENTS

The short-term PM2.5 control measures in the 2012 AQMP included stationary source control 

measures, technology assessments, an indirect source measure and one education and outreach 

measure. The development of the control measures considered the emissions reductions and the 

adoption and implementation dates that would result in attainment of the 2006 24-hour PM2.5 

standard of 35 μg/m3. In some cases, only a range of possible emissions reductions could be 

determined, and for some others, the magnitude of potential reductions could not be determined 

at that time. The short-term PM2.5 control measures were presented in Table 4-2 (Chapter 4) of 

the 2012 AQMP, and the following table, Table F-1 updates that information, thus replacing 

Table 4-2 in the 2012 AQMP for inclusion in the 24-hour PM2.5 SIP. Note that these changes 

do not affect the magnitude or timing of emission reductions commitments supporting the 

attainment demonstration in the 2012 AQMP and this Supplement. The emission reduction 

commitment for CMB-01 (Further NOx Reductions from RECLAIM) was as a contingency 

measure only for PM2.5, and thus does not affect the attainment demonstrations. 

The measures target a variety of source categories: Combustion Sources (CMB), PM Sources 

(BCM), Indirect Sources (IND), Educational Programs (EDU) and Multiple Component Sources 

(MCS).

Two PM2.5 control measures, BCM-01 (Further Reductions from Residential Wood Burning 

Devices) and BCM-02 (Further Reductions from Open Burning), were adopted in 2013 in the 

form of amendments to Rules 445 (Wood Burning Devices) and 444 (Open Burning), 

respectively. Together, these amendments generated a total of 11.7 tons of PM2.5 per day 

reductions on an episodic basis. Control measure CMB-01 (Further NOx Reductions from 

RECLAIM), which was submitted as a contingency measure, is anticipated to be considered by 

the SCAQMD Governing Board in the first half of 2015. The rulemaking process for control 

measure IND-01 (Backstop Measure for Indirect Sources of Emissions from Ports and PortRelated Facilities) is underway, with anticipated SCAQMD Governing Board consideration in 

2015 and the technology assessment for control measure BCM-04 (Further Ammonia Reductions 

from Livestock Waste) will now be adopted in the 2015 to 2016 timeframe with rulemaking to 

follow, if technically feasible and cost-effective. The BCM-03 (Emission Reductions from 

Under-Fired Charbroilers) technology assessment is ongoing and is expected to be completed by 

2015 with rule development to follow by 2017.

Pursuant to CAA Section 172(c)(9), SIPs are required to include contingency measures to be 

undertaken if the area fails to make reasonable further progress or attain the NAAQS by the 

attainment date. The contingency measures “should provide for emission reductions equivalent 

to about one year of reductions needed for reasonable further progress (RFP)” (79 FR 20642-

20645) The 2012 AQMP relied on excess air quality improvement from the control strategy as 

well as potential NOx reductions from control measure CMB-01 (Further NOx Reductions from 
Attachment F: Updated List of Control Strategy Commitments

F -2 February 2015

RECLAIM) to demonstrate compliance with the federal requirement. No additional contingency 

measure commitment is being proposed in this Supplement.
TABLE F-1

Updated 2012 SIP Emission Reduction Commitments to Attain 24-hour PM2.5 NAAQS (35 μg/m3)

2012 AQMP PROPOSED in SUPPLEMENT

Control 

Measure 

#

CONTROL MEASURE TITLE Adoption 

Date

COMMITMENT ACHIEVED Adoption 

Date

COMMITMENT ACHIEVED

2014 2014 2015 2015

PM2.5 EMISSIONS

IND-01 Backstop Measures for Indirect Sources of Emissions 

from Ports and Port-Related Facilities [R4001] 2013 N/A

1 N/A1

2015 N/A

1 N/A1

BCM-01 Further Reductions from Residential Wood Burning 

Devices [R445] 2013 7.1 7.1 2013 7.1 7.1

BCM-02 Further Reductions from Open Burning [R444] 2013 4.6 4.6 2013 4.6 4.6

MCS-01 Application of All Feasible Measures Assessment Ongoing TBD2 TBD Ongoing TBD2 TBD

BCM-03 Emission Reductions from Under-Fired Charbroilers 

[R1138] 2015 TBD3 TBD 2017 TBD3 TBD

EDU-01 Further Criteria Pollutant Reductions from 

Education, Outreach and Incentives Ongoing N/A4 N/A Ongoing N/A4 N/A

TOTAL PM2.5 EMISSION REDUCTIONS (TPD) 11.7 11.7 -- 11.7 11.7

NOx EMISSIONS

CMB-01 Further NOx Reductions from RECLAIM [Reg XX] 2013 2.05-- 2015 2.05--

IND-01 Backstop Measures for Indirect Sources of Emissions 

from Ports and Port-Related Facilities [R4001] 2013 N/A

1 N/A1

2015 N/A

1 N/A1

TOTAL NOx EMISSION REDUCTIONS (TPD) 2.0 -- -- 2.0 --

SOx EMISSIONS

IND-01 Backstop Measures for Indirect Sources of Emissions 

from Ports and Port-Related Facilities [R4001] 2013 N/A

1 N/A1

2015 N/A

1 N/A1

TOTAL SOx EMISSION REDUCTIONS (TPD) -- N/A

1

-- -- N/A

1

NH3 EMISSIONS

BCM-04 

Further Ammonia Reductions from Livestock Waste 

[R1127] - Phase I (Tech Assessment)

2013-

2014 TBD2 TBD 2015 -

2016 TBD2 TBD

-Phase II (Rule Amendment) TBD TBD2 TBD TBD TBD2 TBD

TOTAL NH3 EMISSION REDUCTIONS (TPD) TBD TBD -- -- --

 

1 Measure is designed to ensure reductions assumed to occur will in fact occur

2 Reductions to be determined once the technical assessment is complete, and inventory and control approach are identified

3 Will submit into SIP once technically feasible and cost effective options are identified

4 Reductions cannot be quantified due to the nature of the measure (e.g., outreach, incentive programs)

5 Emission reductions are included in the SIP as a contingency measure, if triggered