January 29, 2009

VIA E-MAIL TO PATRICK AU

Mr. Michael Guzzetta, Manager

Rule Evaluation Section

Emissions Assessment Branch

Stationary Source Division

Air Resources Board

P.O. Box 2815

Sacramento, CA 95812

Subject: SIP Submittal for Revised Rule 102, Definitions, and Rule 316, Storage and Transfer of 

Gasoline

Dear Mr. Guzzetta:

On January 15, 2009, the Santa Barbara County Air Pollution Control District Board of Directors held a 

public hearing on adopting proposed revisions to Rule 102, Definitions, and Rule 316, Storage and 

Transfer of Gasoline. After the public hearing, the Board adopted the revised rules. Transmitted with this 

letter are the adopted revised rules for inclusion in California State Implementation Plan.

The changes to the rules are summarized below:

 Rule 102, Definitions

The APCD modified the definitions of gasoline and organic solvents to update the referenced test 

methods and improve rule clarity. On the gasoline definition, the District added including aviation 

gasoline. Although, Rule 316 does not require the use of a Phase II vapor recovery system when cargo 

tanks refuel aircraft, the rule does require that aviation gasoline bulk plants and cargo tanks be equipped 

with Phase I vapor recovery systems.

 Rule 316, Storage and Transfer of Gasoline

The District added two exemptions to allow vehicle refueling at qualifying gas stations without the use of 

Phase II vapor recovery systems. These exemptions appear in Rule 316, Sections I.7.a and b. Section 

I.7.a provides an exemption to qualifying non-retail gasoline stations that refuel only vehicles equipped 

with onboard refueling vapor recovery systems. Section I.7.b provides an exemption for the refueling of 

flexible fuel vehicles with ethanol (E-85). Other changes to Rule 316 include correcting typos and 

eliminating acronyms, adding three definitions relative to the new exemptions, updating source test 

methods per suggestions from the ARB, and adding test method data for annual certifications of cargo 

tanks per an ARB request.
Santa Barbara County APCD Sip Submittal Page 2

We are providing documents to complete this SIP submittal package as attachments to this letter. These 

attachments included:

1. SIP Completeness Checklist

2. Complete Copies of Rules 102 and 316 (as amended January 15, 2009)

3. Underline and Strikeout Copies of Rules 102 and 316

4. Copy of the Public Notice

5. Signed Resolution and Minute Order

6. Public Comments and Responses

7. Rule Evaluation Form

8. Non-EPA Test Method (ARB Test Method 2-6)

9. Draft Background Paper (September 2008)

We would like to clarify our responses to the SIP Completeness Checklist and the associated material we 

are submitting:

1. The SIP Completeness Checklist requests copies of all referenced rules, unless previously submitted 

as part of an earlier SIP submittal. Our analysis indicates that the District has previously submitted 

all of the referenced rules (201, 326, 802, 803, and 806) as part of earlier SIP submittals. Thus, we 

have not included them with this submittal.

2. Rules 102 and 316 include references to non-EPA test methods. The SIP Completeness Checklist 

indicates we may need to submit such test methods with this package. Our analysis indicates that 

many of the test methods and/or procedures have likely been previously submitted to EPA.

1

 At this 

juncture, in lieu of submitting the test methods, we are providing the following table, which identifies

1) where a rule references a non-EPA test method, 2) the test method name/number, and 3) if 

applicable, where the test method is available on the Internet.2 

 

1 Many of the test methods should be common to other air district rules on gasoline storage, transfer, and vehicle 

refueling.

2

Staff will provide the test method(s) upon request.

Item Rule Test Method Internet Website Where the 

Test Method is Available Other Information

1 102, Gasoline

definition

Test Method for the 

Determination of the Reid 

Vapor Pressure Equivalent 

Using an Automated Vapor 

Pressure Test Instrument

http://ccr.oal.ca.gov/linkedsli

ce/default.asp?SP=CCR1000&Action=Welcome

This test method is found in 

the California Code of 

Regulations, Title 13, 

Division 3, Chapter 5, Article 

4, section 2297. 

2 316, Section 

H.1

ARB Test Method 203, 

CP-203, Certification 

Procedure for Vapor 

Recovery Systems of 

Terminals

http://www.arb.ca.gov/testme

th/vol2/new2006vol2.htm