Antelope Valley Air Quality Management District 43301 Division St., Suite 206 Lancaster, CA 93535-4649 661.723.8070
Fax 661.723.3450 

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Eldon Heaston, Executive Director Air Quality Management District

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.

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Antelope ValleySincerely,

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.