1 Final Staff Report with Appendices for

 Amendments to Rule 4702 

SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

FINAL STAFF REPORT 

Amendments to 

Rule 4702 (Internal Combustion Engines) 

November 14, 2013 

Prepared by: Jesse Madsen, Air Quality Specialist 

Anna Myers, Senior Air Quality Specialist 

 

Reviewed by: Valarie Ballard, Air Quality Inspector II 

Brian Clements, Senior Air Quality Engineer 

Jennifer Ledergerber, Senior Air Quality Inspector 

Jessica Fierro, Program Manager, Strategies and Incentives 

Errol Villegas, Program Manager, Strategies and Incentives 

Samir Sheikh, Director, Strategies and Incentives 

After a thorough evaluation and an extensive public process the San Joaquin Valley 

Unified Air Pollution Control District (District) amended Rule 4702 (Internal Combustion 

Engines) in 2011. This adoption satisfied commitments in the both District’s 2007 

Ozone Plan and 2008 PM2.5 Plan. Since adoption of these amendments, and upon 

further review, it has been determined that some clarification is necessary to more 

clearly align rule language with the intent of the 2011 rule amendments. 

The four-year rule amendment process for the 2011 amendments included a feasibility 

study; research of the District’s permits database, industry standards, technological 

advancements and actions taken by other regulatory agencies; and evaluation of public 

comments received throughout the public process including four public workshops, 

several stakeholder technical discussion meetings and socioeconomic focus group 

meetings. These extensive efforts resulted in the adoption of numerous technologically 

feasible and cost effective new and more stringent rule requirements. Through this 

process, the District made the determination that reducing the NOx emission limits for 

waste gas fueled internal combustion engines is not feasible, and therefore proposed no 

amendments to the NOx emission limits for these engines. 

The purpose of this current rule amending project is to make administrative updates to 

rule language to clarify existing rule requirements by adding Federal Register citations 

to Section 3.37, deleting “stationary” from Section 5.2, deleting “the” from Section 

5.10.2, adding “and” to Section 7.5.2.1, adding “source” to Section 7.6.2.2, and by 

adding a line item to Table 2 to clarify that NOx limits for lean-burn waste gas fired 

engines used exclusively in non-Agricultural Operations (Non-AO) is 65 parts per million 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Final Staff Report: Rule 4702 November 14, 2013 

2 Final Staff Report with Appendices for

 Amendments to Rule 4702 

by volume (ppmv). This rule amending project would not change existing emissions 

limits or affect air quality. 

AMENDMENTS TO RULE 4702 

The administrative rule clarifications are as follows. 

Applicability 

During the rule amendment project for the 2011 amendments, the word “stationary” was 

added to Section 5.2, as this section is applicable to all engines rated at greater than 50 

brake horsepower (bhp) that are operated as a part of a stationary source. However, 

the addition of the term stationary could be misinterpreted by stakeholders to mean that 

requirements in Section 5.2 are limited to stationary engines. Additionally, we believe 

this word was carried over from Section 5.1, which is intended to provide an inventory of 

small stationary engines, and so the word “stationary” is less likely to be misinterpreted 

there. The amendments removed the word “stationary” from Section 5.2 to ensure the 

intent of the language is not misinterpreted. This clarification does not result in a 

change to currently enforced rule requirements or applicability. 

NOx Limits for Lean-Burn Waste Gas Fired Engines 

Section 5.2.2 Table 2 would be amended to clarify the NOx limit for waste-gas fueled 

lean burn engines used exclusively in Non-AO. The addition of this line item would 

clarify the existing 65 ppmv limit for these engines, originally presented in Table 1 line 

item 2.b of the 2007 version of the rule. 

During the 2011 rule amendment project, the District determined that further reducing 

the NOx emission limits for waste gas fueled internal combustion engines goes beyond 

RACT due to significant technical difficulties and prohibitive costs associated with the 

inherent heat content variability of waste gas. It was therefore decided that no 

amendments would be proposed to reduce the NOx emission limits for these engines. 

This decision is explained in several instances throughout the Governing Board Memo, 

CEQA Initial Study, and Final Draft Staff Report with Appendices1

, and the presentation2

at the public hearing for adoption of proposed amendments: 

• Governing Board Memo, pages three, eight and nine 

• The CEQA Initial Study and Final Negative Declaration for Proposed 

Amendments to Rule 4702, page eight 

• Final Draft Staff Report, pages three and ten 

• Appendix B (Emission Reduction Analysis), page B-6 

 

1

 August 18, 2011 Memo to SJVUAPCD Governing Board (2011). Retrieved September 25, 2013 from 

http://www.valleyair.org/Board_meetings/GB/agenda_minutes/Agenda/2011/August/Agenda_Item_10_Aug_18_2011.

pdf 

2

 August 18, 2011 Presentation to SJVUAPCD Governing Board (2011). Retrieved September 25, 2013 from 

http://www.valleyair.org/Board_meetings/GB/agenda_minutes/Agenda/2011/August/R4702PresentationGB.pdf 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Final Staff Report: Rule 4702 November 14, 2013 

3 Final Staff Report with Appendices for

 Amendments to Rule 4702 

• Appendix C (Cost Effectiveness Analysis), pages C-4 and C-5 

• Appendix D (Socioeconomic Analysis), page D-7 

• Presentation to the Governing Board, slides four and seven 

The line-item clarification for lean-burn waste gas fired engines used exclusively in NonAO was added to Table 2 of Rule 4702; see below. 

Updated Table 2 for Rule 4702 Emission Limits for Internal Combustion Engines 

Table 2 Emission Limits for a Spark-Ignited Internal Combustion Engine Rated at >50 bhp 

Used Exclusively in Non-AO (All ppmv limits are corrected to 15% oxygen on a dry 

basis). Emission Limits are effective according to the compliance schedule specified 

in Section 7.5. 

Engine Type NOx Limit 

(ppmv) 

CO Limit 

(ppmv) 

VOC Limit 

(ppmv) 

1. Rich-Burn 

a. Waste Gas Fueled 50 2000 250 

b. Cyclic Loaded, Field Gas Fueled 50 2000 250 

c. Limited Use 25 2000 250 

d. Rich-Burn Engine, not listed above 11 2000 250 

2. Lean-Burn Engines 

a. Two-Stroke, Gaseous Fueled, >50 bhp 

and < 100 bhp 75 2000 750 

b. Limited Use 65 2000 750 

c. Lean-Burn Engine used for gas 

compression 

65 ppmv or 

93% reduction 2000 750 

d. Lean-Burn Engine, Waste Gas Fueled 65 ppmv or 

90% reduction 2000 750 

ed. Lean-Burn Engine, not listed above 11 2000 750 

ANALYSES 

This rule amending project is an administrative clarification of existing rule 

requirements; amendments do not result in new or more stringent regulatory controls 

and do not affect air quality or emission limitations. No emission reductions or costs are 

associated with this rule-amendment project. Therefore, this rule amending project 

does not require a socioeconomic impact analysis (CH&SC § 40728.5(a)), a rule 

consistency analysis (CH&SC § 40727.2), or a CEQA analysis (CEQA guidelines § 

15060). 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Final Staff Report: Rule 4702 November 14, 2013 

4 Final Staff Report with Appendices for

 Amendments to Rule 4702 

RULE DEVELOPMENT PROCESS 

The District made the Proposed Amendments to Rule 4702 and the Final Draft Staff 

Report available for review and public comment 30 days prior to a public hearing of the 

Governing Board to consider adoption of the proposed rule amendments. No 

comments were received during the subsequent two-week comment period. The 

proposed amendments were presented to the Governing Board for adoption at a public 

hearing on November 14, 2013. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix A: Comments and Responses November 14, 2013 

A - 1 Final Staff Report with Appendices for 

Amendments to Rule 4702 

APPENDIX A 

Summary of Significant Comments and Responses 

For Amendments to Rule 4702 

November 14, 2013 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix A: Comments and Responses November 14, 2013 

A - 2 Final Staff Report with Appendices for 

Amendments to Rule 4702 

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SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix A: Comments and Responses November 14, 2013 

A - 3 Final Staff Report with Appendices for 

Amendments to Rule 4702 

SUMMARY OF SIGNIFICANT COMMENTS FOR 

PROPOSED AMENDMENTS TO RULE 4702 (INTERNAL COMBUSTION ENGINES) 

EPA REGION IX COMMENTS 

No comment letter was received from EPA. 

ARB COMMENTS 

No comment letter was received from ARB. 

STAKEHOLDER COMMENTS 

No stakeholder comments were received.
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix A: Comments and Responses November 14, 2013 

A - 4 Final Staff Report with Appendices for 

Amendments to Rule 4702 

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