Antelope Valley Air Quality Management District 

43301 Division St., Suite 206 

Lancaster, CA 93535-4649 

661.723.8070 

Fax 661.723.3450 

KnteldOWNIley 

Air Quality Management District Eldon Heaston, Executive Director 

August 17, 2015 

Carol Sutkus 

State of California 

Environmental Protection Agency 

Air Resources Board 

P. O. Box 2815 

Sacramento, California 95812 

Project Title: Adoption of AVAQMD 2015 8-Hour Reasonably Available Control 

Technology — State Implementation Plan Analysis (2015 RACT SIP Analysis) 

Dear Ms. Sutkus: 

The Antelope Valley Air Quality Management District (AVAQMD) requests that the California 

Air Resources Board submit the AVAQMD 2015 8-Hour Reasonably Available Control 

Technology — State Implementation Plan Analysis (2015 RACT SIP Analysis) to the United 

States Environmental Protection Agency (USEPA) for inclusion in the State Implementation 

Plan (SIP). 

The Federal Clean Air Act (FCAA) requires areas designated non-attainment and classified 

moderate and above to implement Reasonably Available Control Technology (RACT) for 

sources subject to Control Technique Guidelines (CTG) documents issued by the USEPA for 

"major sources" of volatile organic compounds (VOCs) and oxides of nitrogen (NO) which are 

ozone precursors. Effective May 27, 2008 (73 FR 16436, March 27, 2008), USEPA lowered the 

primary ozone National Ambient Air Quality Standard (NAAQS) from 0.084 parts per million 

(ppm) to 0.075 ppm. For purposes of the FCAA, the District has been designated non-attainment 

for ozone and classified as Severe-15 for the new 8-hour ozone standard. As a result of this 

change, USEPA is requiring that all non-attainment areas adopt and submit an updated RACT 

SIP Analysis to ensure that District Rules adequately address current RACT requirements. 

In 2006 the AVAQMD adopted the 8-Hour Reasonably Available Control Technology — State 

Implementation Plan Analysis (RACT SIP Analysis) in response to change on March 9, 2006 of 

the previous ozone standard from measurement on a one- hour basis (1-hour ozone standard) to 

an eight-hour basis (8-hour ozone standard). On September 11, 2006, USEPA provided 

comments on the 2006 RACT SIP Analysis requesting additional analysis on several rules to 

determine if they still represented RACT. On March 13, 2014, the AVAQMD sent the 2014 

Supplement to the 2006 AVAQMD RACT SIP Analysis addressing these comments and providing 

the requested analysis of those rules identified by USEPA. This update was not acted on by the 

Governing Board pursuant to USEPA direction. 

Printed on recycled paper 

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Cities 

Antelope Valley 
Sincerely, 

Alan J. Be Salvio 

Deputy Director — Mojave Desert Operations 

AJD/tw AV CARB SIP Submittal Request 2015 RACT SIP 

Ms. Sutkus Page 2 

The AVAQMD has now adopted an updated 2015 RACT SIP Analysis for the 2008 0.075 ppm 8-

hour ozone NAAQS. The information contained in the original 2006 RACT SIP Analysis, the 

information in the supplemental 2014 RACT SIP Analysis, together with this document, will 

comprise an analysis sufficient to satisfy the RACT SIP Analysis request for the 0.075 ppm 8-

hour ozone NAAQS. 

If you have any questions regarding this submittal, please contact me at (760) 245-1661, 

extension 6726, or Tracy Walters at extension 6122. Please note that all documents required for 

a complete submission were sent electronically on August 17, 2015.