SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT

Final Staff Report for

PROPOSED AMENDED RULE 1110.2 -- EMISSIONS FROM GASEOUS- AND 

LIQUID-FUELED INTERNAL COMBUSTION ENGINES AND 

RESCISSION OF RULE 1110.1 – EMISSIONS FROM STATIONARY 

INTERNAL COMBUSTION ENGINES

May 2005

Deputy Executive Officer

Planning, Rule Development, and Area Sources

Elaine Chang, DrPH

Assistant Deputy Executive Officer

Planning, Rule Development, and Area Sources

Laki Tisopulos, Ph.D., P.E.

Authors: Martin Kay, P.E., M.S., Program Supervisor

Alfonso Baez, M.S., Senior Air Quality Engineer

Howard Lange, Ph.D., Air Quality Engineer II

Reviewed by: Barbara Baird, Principal Deputy District Counsel

Technical Assistance: Chris Abe, Air Quality Specialist

Kien Huynh, Air Quality Engineer II

Shams Hasan, Air Quality Specialist
SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT

GOVERNING BOARD

Chair: WILLIAM A. BURKE, Ed.D.

Speaker of the Assembly Appointee

Vice Chair: S. ROY WILSON, Ed.D.

Supervisor, Fourth District

Riverside County Representative

MEMBERS:

MICHAEL D. ANTONOVICH

Supervisor, Fifth District

Los Angeles County Representative

JANE W. CARNEY

Senate Rules Committee Appointee

MIGUEL PULIDO

Mayor, City of Santa Ana

Cities Representative, Orange County

BEATRICE J. S. LAPISTO-KIRTLEY

Mayor, City of Bradbury

Cities Representative, Los Angeles County/Eastern Region

RONALD O. LOVERIDGE

Mayor, City of Riverside

Cities Representative, Riverside County

JAN PERRY

Councilmember, 9th District

Cities Representative, Los Angeles County, Western Region

GARY OVITT

Supervisor, Fourth District

San Bernardino County Representative

JAMES SILVA 

Supervisor, Second District

Orange County Representative

CYNTHIA VERDUGO –PERALTA

Governor’s Appointee

DENNIS YATES

Councilmember, City of Chino

Cities Representative, San Bernardino County

EXECUTIVE OFFICER

BARRY R. WALLERSTEIN, D.Env.
TABLE OF CONTENTS

ii May 2005

BACKGROUND .................................................................................................................1

South Coast Air Quality Management District........................................................1

SB700- Agricultural Operations..............................................................................1

Current Rule 1110.2.................................................................................................2

RECLAIM................................................................................................................2

USEPA Regulations.................................................................................................2

CARB Regulations and Guidance ...........................................................................5

AFFECTED SOURCES/EMISSIONS INVENTORY........................................................6

AQMD Agricultural Operations Survey..................................................................7

Portable Engines ......................................................................................................8

Stationary Non-Agricultural Engines ......................................................................8

CONTROL TECHNOLOGY ..............................................................................................8

Diesel Engine Emissions and Emission Control Technologies...............................9

Spark-Ignition (SI) Engine Emissions and Emission Control Technologies...........9

Other Technology Options.....................................................................................13

PROPOSED AMENDMENTS..........................................................................................14

Exemptions – Subdivision (h)................................................................................14

Requirements – Subdivision (d).............................................................................16

Compliance – Subdivision (e)................................................................................17

Monitoring and Recordkeeping – Subdivision (f) .................................................17

Test Methods – Subdivision (g).............................................................................18

Technology Assessment for PM2.5 - Subdivision (h).............................................18

Definitions – Subdivision (c).................................................................................18

EMISSIONS IMPACTS....................................................................................................19

Stationary Non-Emergency Engines in Agricultural Operations...........................19

Portable Engines ....................................................................................................20

COST-EFFECTIVENESS.................................................................................................20

State Law Requirements........................................................................................20

Cost-Effectiveness Calculations ............................................................................20

Cost-Effectiveness Comparisons...........................................................................21

Incremental Cost-Effectiveness.............................................................................27
TABLE OF CONTENTS

iii May 2005

CALIFORNIA ENVIRONMENTAL QUALITY ACT....................................................28

SOCIOECONOMIC ASSESSMENT................................................................................28

Affected Facilities..................................................................................................28

Compliance Costs ..................................................................................................29

Potential Impact of fees on Agricultural Sources..................................................30

COMPARATIVE ANALYSIS..........................................................................................32

Existing Federal Requirements..............................................................................32

AQMD Rules Applying to Gaseous and Liquid-Fueled Engines..........................38

PERMITTING RECOMMENDATIONS..........................................................................39

DRAFT FINDINGS...........................................................................................................40

REFERENCES ..................................................................................................................41

APPENDIX A – COST-EFFECTIVENESS CALCULATIONS................................... A-1

APPENDIX B - INCENTIVE FUNDING AVAILABLE FOR .....................................B-1

AGRICULTURAL ENGINE EMISSION REDUCTIONS

APPENDIX C - SB 700 EXCERPTS..............................................................................C-1

APPENDIX D - STATIONARY, NON-EMERGENCY AGRICULTURAL ENGINES 

EMISSIONS INVENTORY........................................................................................... D-1

APPENDIX E - EMISSION IMPACTS..........................................................................E-1

APPENDIX F - PUBLIC COMMENTS AND RESPONSES ........................................F-1
Final Staff Report for Proposed Amended Rule 1110.2

1 May 2005

BACKGROUND

South Coast Air Quality Management District

The South Coast Air Quality Management District (AQMD) is the air pollution control agency 

for all of Orange County and the urban portions of Los Angeles, Riverside and San Bernardino 

counties. This area of 10,000 square miles is home to nearly 16 million people. It is the second 

most populated urban area in the United States and one of the smoggiest.

AQMD is responsible for controlling emissions primarily from stationary sources of air 

pollution. These can include anything from large power plants and refineries to the local dry 

cleaner. About 23% of this area's ozone-forming air pollution comes from stationary sources, 

both businesses and residences. The remaining 77% comes from mobile sources-- primarily 

cars, trucks and buses in addition to construction equipment, ships, trains and airplanes. 

Emission standards for mobile sources are established by the state or federal agencies, such as 

the California Air Resources Board (CARB) and the U.S. Environmental Protection Agency 

(EPA), rather than by local agencies such as the AQMD.

Under the Federal Clean Air Act, EPA establishes health-based air quality standards that all 

states must achieve. The California Clean Air Act also establishes requirements for cities and 

counties to meet. AQMD develops plans and regulations designed to achieve these public health 

standards by reducing emissions from business and industry. AQMD's strategy of combined 

emission reduction of Volatile Organic Compound (VOC) and Oxides of Nitrogen (NOx) is 

intended to move the AQMD towards the attainment of all federal air quality standards and 

improve the public health by reducing public exposure to high concentrations of air 

contaminants. Additional emission reductions of NOx are required to attain and maintain several 

state and federal standards, including those for ozone, NO2, particulate matter (PM), and 

visibility.

SB700 - Agricultural Operations

Until recently, local air districts were prohibited from requiring permits for agricultural 

operations such as farms, orchards, ranches, dairies and other confined animal feeding 

operations. Even conventional equipment such stationary engines and gasoline storage and 

dispensing equipment were exempt from rules that required other types of facilities using them to 

control their emissions. Agricultural operations represent a significant source of air pollution 

throughout the state. Emissions from agricultural sources for calendar year 2003 are estimated to 

be more than 13 tons per day of VOCs, 8 tons per day of NOx, and over 3 tons per day of PM10 

in the SCAQMD. Some agricultural operations are major sources of air pollution which federal 

law (Title V) requires to be subject to air permits. The U.S. EPA proposed disapproving 

California’s Title V permitting program because of the agricultural exemption and the significant 

source of air pollution that agricultural operations represent. 

Because of the need in California to reduce emissions from and require permits for agricultural 

operations, Senate Bill 700 – Agricultural Air Quality (SB 700) was enacted into law on January 

1, 2004, amending California Health and Safety Code Section 42310 and adding Sections 

39011.5, 39023.3, 40724, 40724.5, 40724.6, 40724.7, 40731, 42301.16, 42301.17, 42301.18, and 

44559. Section 42301.16 eliminated the exemption from the permit system of local air pollution 
Final Staff Report for Proposed Amended Rule 1110.2

2 May 2005

control districts of certain large agricultural operations. Other sections required rules to be 

adopted to reduce emissions from conventional equipment like engines and gasoline tanks, and 

strictly agricultural operations like confined animal feeding operations. Under SB700 all areas 

of the state which are designated as "serious" non-attainment for federal PM10 standards are 

required to implement:

1) Best Available Control Measures (BACM) to reduce emissions from non-traditional and 

non-point sources of PM10. These sources include tilling, composting, discing, 

cultivation, harvesting, raising of animals, etc. AQMD's PAR 403 and PAR 1127.1 will 

address these sources.

2) Best Available Retrofit Control Technology (BARCT) to reduce emissions from 

traditional point sources. These point sources include IC engines, boilers, gasoline 

fueling and dispensing, etc. AQMD’s PAR 1110.2 and PAR 461 are intended to address 

these requirements.

Appendix B describes the new incentive programs that will help agricultural operations comply 

with new and modified rules that will apply to agricultural operations. Agricultural operations 

are unique in that state law allows only agricultural operations to receive incentive funding to 

comply with local air district rules. Other types of facilities may only receive funding for 

voluntary emission reductions not required by a local rule. 

Current Rule 1110.2

Rule 1110.2 was adopted in August 1990 to control NOx, carbon monoxide (CO), and VOC 

from gaseous and liquid-fueled internal combustion engines (ICEs). For all stationary and 

portable engines over 50 bhp, it required that either 1) NOx emissions be reduced over 90% to 

one of two compliance limits specified by the rule, or; 2) the engines be permanently removed 

from service or replaced with electric motors. It was amended in September 1990 to clarify rule 

language. It was then amended in August and December of 1994 to modify the CO monitoring 

requirements and to clarify rule language. The latest amendment in November of 1997 

eliminated the requirement for continuous monitoring of CO, reduced the source testing 

requirement from once every year to once every three years, and exempted nonroad engines, 

including portable engines. Agricultural engines are exempt from the current rule. 

RECLAIM

In 1993 AQMD adopted Regulation XX – Regional Clean Air Incentives Market (RECLAIM). 

This regulation established NOx and SOx trading market emission reduction program that 

allowed over 300 of the largest sources in AQMD to meet the requirements of that program 

rather than the NOx requirements of other AQMD Rules. Therefore, some engines in AQMD 

are not subject to the NOx requirements of Rule 1110.2. They are still subject to the VOC and 

CO requirements.

USEPA Regulations

New Source Performance Standards

Because of a Consent Decree, USEPA is working on developing New Source Performance 

Standards for new, stationary compression-ignition (CI or diesel) engines and spark- ignition (SI) 

engines. The Consent Decree requires standards is for CI engines be proposed in June of 2005 
Final Staff Report for Proposed Amended Rule 1110.2

3 May 2005

and promulgated in June of 2006; and standards for SI engines be proposed in May of 2006 and 

promulgated in December of 2007. 

National Emission Standards for Hazardous Air Pollutants

The recent final rule1for stationary reciprocating internal combustion engines (RICE) at major 

sources of hazardous air pollutants requires that:

 Existing and new 4-stroke rich burn (4SRB) engines either reduce formaldehyde by 76 

percent or limit the formaldehyde concentration to 350 parts per billion.

 New 2-stroke lean burn (2SLB) engines either reduce carbon monoxide (CO) by 58 

percent or limit the formaldehyde concentration to 12 parts per million.

 New 4-stroke lean burn (4SLB) engines either reduce CO by 93 percent or limit the 

formaldehyde concentration to 14 parts per million.

 New compression ignition (CI) engines either reduce CO by 70 percent or limit the 

formaldehyde concentration to 580 parts per billion.

Formaldehyde and CO are surrogates for reducing the air toxics of concern from RICE.

Therefore, by reducing formaldehyde and CO, facilities also will reduce the other air toxics to 

similar levels.

USEPA expects owners or operators of 4SRB engines to install air pollution control devices 

known as non-selective catalyst reduction (3-way catalyst). Owners or operators of 2SLB, 

4SLB, and CI engines likely will install devices known as CO catalytic oxidation systems to 

meet the formaldehyde and CO requirements.

Nonroad Engines

USEPA regulates new nonroad engines. Nonroad engines include: engines that propel offroad 

equipment such as trains and bulldozers, and; portable engines that drive generators and wood 

chippers and other equipment, and that are moved from place to place. Nonroad engines 

includes CI and SI engines using diesel fuel, propane, gasoline and other fuels.

The Nonroad Preemption

The Clean Air Act Amendments of 1990 limit the ability of states and local districts to regulate 

nonroad engines. Only USEPA can set emission standards for new construction and farm 

equipment under 17570 hp. Federal regulations2allow California to regulate all other nonroad 

engines with an authorization from USEPA. States and local districts can also regulate the use of 

nonroad engines. As amended by USEPA in December 1997, the preemption applies to all 

nonroad engines, regardless of their date of manufacture.

Nonroad Diesel Engine Regulations 

USEPA has been regulating new nonroad diesels since 1996 in 40 CFR 89 Subpart A, Appendix 

A and 40 CFR 85 Subpart Q. Tier 1, Tier 2 and Tier 3 standards are in effect or are partly in 

effect, and recently adopted and stringent Tier 4 standards will go into effect in the next decade. 

The emission standards vary by engine size, but as an example Table 1 shows the standards for 

nonroad diesel engines from 100 ≤ hp < 175.

 

1

40 CFR 63 Subpart ZZZZ

2

40 CFR 89, Subpart A, Appendix A and 40 CFR 85, Subpart Q
Final Staff Report for Proposed Amended Rule 1110.2

4 May 2005

Table 1. USEPA Nonoad Diesel Engine Emission Standards

175 ≤ hp < 300 (grams/bhp-hr)

Implementation 

Date

CO NMHC NOx + 

NMHC

NOx PM

Tier 1 1996 8.5 1.0 - 6.9 -

Tier 2 2003 2.6 - 4.9 - 0.15

Tier 3 2006 2.6 - 3.0 - 0.15

Tier 4 2012-2014 2.6 0.14 - 0.30 0.015

Figure 1 demonstrates the remarkable emission reductions that the Tier 4 emission limits will 

achieve. These limits are more stringent than Rule 1110.2.

Figure 1. USEPA Nonroad Diesel Emission Standards for a 175 hp Engine

Nonroad Spark-Ignited (SI) Engine Regulations

USEPA has been regulating new nonroad SI engines over 25 Hp since 2004 in 40 CFR 1048. 

Most of these engines use liquefied petroleum gas (propane), with others operating on gasoline 

or natural gas. USEPA adopted two tiers of emission standards (see Table 2). The first tier of 

standards, which started in 2004, are based on a simple laboratory measurement using steadystate procedures. The Tier 1 standards are the same as those adopted earlier by CARB for 

engines used in California. The Tier 2 standards, starting in 2007, are based on transient testing 
Final Staff Report for Proposed Amended Rule 1110.2

5 May 2005

in the laboratory, which ensures that the engines will control emissions when they operate under 

changing speeds and loads in the different kinds of equipment. USEPA includes an option for 

manufacturers to certify their engines to a less stringent CO standard if they certify an engine 

with lower HC+NOx emissions. In addition to these exhaust-emission controls, manufacturers 

must take steps starting in 2007 to reduce evaporative emissions, such as using pressurized fuel 

tanks.

Table 2. USEPA SI Engine Emission Standards (grams/bhp-hr)

Implementation Date HC + NOx CO

Tier 1 2004 3.0 37

Tier 2 2007 2.0 4.4

Starting with Tier 2, USEPA adopted additional requirements to ensure that engines control 

emissions during all kinds of normal operation in the field. Tier 2 engines must have engine 

diagnostic capabilities that alert the operator to malfunctions in the engine’s emission-control 

system.

CARB Regulations and Guidance

CARB Guidance for Stationary Spark-Ignited Engines

In 2001, CARB published “Determination of Reasonably Available Control Technology and 

Best Available Retrofit Control Technology for Stationary Spark-Ignited Internal Combustion 

Engines” as guidance for local air districts in adopting rules for stationary spark-ignited engines. 

Because of compliance problems with engines, it recommended more frequent source testing 

than Rule 1110.2, and an Inspection and Monitoring Plan requiring periodic monitoring and 

maintenance, including the use of a portable emission analyzer. 

Air Toxic Control Measures for Diesel Engines

CARB has adopted Air Toxic Control Measures (ATCMs) for both stationary and portable diesel 

engines. The purpose of these ATCMs is primarily to reduce diesel PM, but they will result in 

some reductions the other pollutants as well. AQMD has adopted its version of the stationary 

diesel ATCM in the form of Rule 1470. 

Existing stationary agricultural engines were not subject to the stationary diesel ATCM, but 

CARB has begun staff work on an ATCM for this equipment.

CARB Portable Equipment Registration Program (PERP) Regulation

Health & Safety Code Sections 41750-41755 (Assembly Bill 531), effective January 1, 1996, 

require the CARB to adopt regulations to establish a statewide registration program for portable 

engines and other equipment. The regulation was adopted on March 27, 1997 by CARB. 

Portable engine owners or operators may register under the statewide program or permit with the 

AQMD. Those that register with CARB are exempt from AQMD permits and emission 

requirements.

Presently, CARB's statewide PERP has an exemption/prohibition for agricultural portable 

equipment. CARB's PERP regulations prohibit allowing agricultural sources' portable 

equipment to register under PERP, unless a local air district adopts or amends its rules to allow 
Final Staff Report for Proposed Amended Rule 1110.2

6 May 2005

state registration in lieu of local permits. AQMD has not done this, so portable agricultural 

engines that are subject to permit (not exempt per Rule 219) will be subject to AQMD permits 

only. It is very important to note that sources may still need to comply with applicable rules, 

such as 1110.2, even if permits are not required.

Off-Road Diesel Engines

CARB began regulating new off-road3diesel engines before USEPA, but later harmonized its 

regulations in Title 13, Chapter 9, Article 4 of the California Code of Regulations (CCR) with 

USEPA nonroad diesel emission standards. On December 9, 2004 CARB approved amendments 

to incorporate USEPA Tier 4 standards into state law, although the regulation is not final until 

approved by the Office of Administrative Law. The emission standards will be the same as 

USEPA’s, but there are some minor differences in other areas.

Off-Road Spark-Ignited (SI) Engines

CARB has been regulating new off-road SI engines over 25 hp since 2001 in Title 13, CCR, 

Chapter 9, Article 4.5. The emission standards are shown in Table 3.

Table 3. CARB Offroad SI Engine Emission Standards (grams/bhp-hr)

Implementation 

Date

Engine 

Displacement

HC + NOx CO

2002  1.0 Liters 9.0 410

2001-2003 > 1.0 Liters 3.0 37

These standards are less stringent than EPA standards that went into effect in 2004 (see earlier 

discussion.) However, CARB staff is working on, and has begun workshops for, new regulations 

to reduce emissions from both new and in-use off-road SI engines. 

AFFECTED SOURCES / EMISSIONS INVENTORY

PAR 1110.2 applies to stationary and portable internal combustion engines (ICEs) over 50 brake 

horsepower (bhp). ICEs generate power by combustion of an air/fuel mixture. In the case of 

spark-ignited (SI) engines, a spark plug ignites the air/fuel mixture while a diesel engine relies on 

heating of the inducted air during the compression stroke to ignite the injected diesel fuel. Most 

stationary and portable ICEs are used to power pumps, compressors, or electrical generators. 

SI engines come in a wide variety of designs such as: two-stroke and four-stroke, rich-burn and 

lean-burn, turbocharged and naturally-aspirated. SI engines can use one or more fuels, such as 

natural gas, oil field gas, digester gas, landfill gas, propane, butane, liquefied petroleum gas 

(LPG), gasoline, methanol and ethanol. ICEs can be used in a wide variety of operating modes 

such as: Emergency operation (i.e. used only during testing, maintenance, and emergencies), 

seasonal operation, continuous operation, continuous power output, and cyclical power output.

Uncontrolled ICEs, even when burning a clean fuel such as natural gas, have extremely high 

emissions of NOx, CO and HC. Diesel engines not only have significant NOx emissions but also 

emit particulate matter (PM) which has been identified as a Toxic Air Contaminant (TAC) by the 

 

3 USEPA uses the term nonroad for the same purpose. 
Final Staff Report for Proposed Amended Rule 1110.2

7 May 2005

CARB. Once a substance is identified as a TAC, the CARB is required by law to determine if 

there is a need for further control. CARB recently approved Airborne Toxic Control Measures 

(ATCM) for stationary and portable diesel engines. CARB is currently developing an ATCM for 

in-use stationary diesel agricultural engines.

AQMD Agricultural Operations Survey

In order to obtain more information about agricultural sources in AQMD, staff developed a 

simple one page Agricultural Operations survey form that was mailed out to a total of 1,925

agricultural operations in April and June 2004. The survey basically consisted of nine "Yes/No/ 

How Many?" type questions regarding size of dairy or poultry farm and of equipment that would 

traditionally be found in agricultural operations such as ICEs , boilers, heaters, gasoline 

dispensing/storage, grain conveyor/silo, degreasers and paint spray equipment. The mailing lists 

were provided directly to a Clearinghouse mailing service by the contacted associations (Western 

United Dairymen, Pacific Egg and Poultry Association, Los Angeles County Farm Bureau, San 

Bernardino County Farm Bureau, Orange County Farm Bureau, Riverside County Farm Bureau 

and other agricultural groups) and the Regional Water Quality Control Boards that recently 

passed rules regarding dairy runoff. The mailing lists were not made available to the AQMD. 

885 (46%) survey forms were returned to AQMD with only 473 providing minimal information 

for statistical purposes.

Of the 473 surveys, 17 facilities reported using 8 stationary and 5 portable ICEs for irrigation 

pumps, 11 stationary and 6 portable ICEs for well-water pumps and one stationary ICE for a 

cattle feed mixer. Since PAR 1110.2 still exempts emergency stand-by engines and wind 

machines from emission controls, only irrigation pumps, well-water pumps and other nonexempt engines will be included in the agricultural engine emissions inventory which will 

consist of 12 facilities. Follow up contacts with sites that responded to the survey have indicated 

that all existing stationary SI engines and most existing stationary diesel engines are uncontrolled 

(Tier 0).

Based on the results of this survey and other information provided by agricultural associations 

and trade groups, the emissions from the 20 surveyed stationary engines was determined to be as 

presented in Table 4. Exactly one half of the 20 engines are diesel, and the other half natural gas 

SI engines. The detailed calculations are shown in Appendix D.

However, this survey may be underestimating the actual emissions due to the 46% survey 

response. The emissions inventory from stationary engines in agricultural operations will be 

estimated based on the following assumptions:

1. Double the emissions from the survey response since approximately 1/2 of the surveys did 

not respond.

2. The other half of the surveys are assumed to have the same engine statistics.

Therefore, the estimated uncontrolled emissions inventory from all stationary engines in 

agricultural operations are as shown in Table 5.
Final Staff Report for Proposed Amended Rule 1110.2

8 May 2005

Table 4. Stationary Agricultural Engines Survey

Engine Class Average 

HP

Engines Annual Emissions (Tons/Year)

NOx VOC CO PM

Irrigation 

Pumps

120 8 14.1 1.10 3.73 0.975

Well/Water 

Pumps

209 11 56.4 2.79 48.8 2.42

Other 

Engines

210 1 1.14 0.164 1.40 0.0658

TOTALS 20 71.6 4.05 53.9 3.46

Table 5. Estimated Emissions Inventory from Stationary Engines 

in Agricultural Operations 

(tons/year)

NOx VOC CO PM

143.0 8.1 108.0 6.92

Portable Engines

CARB estimates that in 2000 17,500 portable diesel engines in California emitted 67.1 tons/day 

of NOx, 6.7 tons/day of ROG and 4.2 tons/day of PM. Emissions in SCAQMD would be about 

45% of this amount. These emissions should gradually decline as newer CARB-certified 

portable engines replace older, higher emitting engines. 

Stationary Non-Agricultural Engines

The 1990 staff report for proposed Rule 1110.2 estimated that Rule 1110.2 would reduce NOx 

emissions of 1,289 stationary, non-emergency engines from 28.0 tons/day to 2.9 tons/day. The 

proposed amendments will not affect stationary, non-agricultural emissions.

CONTROL TECHNOLOGY

Stationary agricultural engines coming into Rule 1110.2, fall into two major categories: (1) 

compression ignition, i.e., diesel-fueled, engines and (2) SI engines, which may be fueled by 

propane, natural gas or gasoline. Since agricultural engines have heretofore been unregulated, 

most have no emission controls. In order to comply with Rule 1110.2, owners of these engines 

will have to install emission controls, replace the engine with a controlled SI engine, or replace 

the engine with an electric motor.
Final Staff Report for Proposed Amended Rule 1110.2

9 May 2005

Diesel Engine Emissions and Emission Control Technologies

U.S. EPA AP-424lists uncontrolled industrial diesel engine emission factors in terms of g/hp-hr 

as 14.0 for NOx, 3.03 for CO, and 1.12 for VOC. Since 1996, nonroad diesel engines have been 

regulated at the federal and state levels through a certification program requiring that the 

manufacturers certify their engine models to meet certain emission standards, which become 

progressively more stringent over time. California’s nonroad emission standards are the same as 

the federal nonroad standards. The nonroad emission standards for gaseous pollutants are shown 

in Table 6. The Tier 4 engines over 75 hp would comply with Rule 1110.2, but they will not be 

available until 2014. The existing agricultural diesel engines coming into the rule are likely to be 

“Tier 0”, i.e., uncertified. However, agricultural engines purchased since 1996 may be Tier 1 or 

even Tier 2, if purchased new after 2000.5.

Add-on control technologies that are suitable for diesel engines include selective catalytic 

reduction (SCR) control systems for NOx and oxidation catalysts for reduction of CO and VOC. 

Both of these technologies have been successfully applied to diesel engines. SCR involves 

injection of urea or ammonia into the flue gas upstream of the catalyst and results in emissions of 

small amounts of unreacted ammonia. Application of these technologies to a large Tier 1 diesel 

engine located at a ski resort in the AQMD achieved the NOx, CO and VOC emissions shown in 

Table 7. Assuming that the engine was designed for emissions to be approximately 20% below 

the Tier 1 standards, the apparent emission reductions achieved by the technologies are 90% for 

NOx, 99% for CO and 74% for VOC. Because of the high costs of the add-on control equipment 

for a diesel engine, compared to a SI engine, few diesels were retrofitted to comply with Rule 

1110.2. Some became subject to the RECLAIM program, and others were removed from 

service.

Emulsified fuel is another technology that can be applied to a stationary diesel engine. 

Emulsified fuel contains water, which has been blended into the fuel using appropriate blending 

equipment and an additive to create a stable mixture. Separation of the water can, however, 

occur if the fuel is in storage for too long. Presence of water in the fuel improves combustion 

while also lowering the flame temperature. It has been applied primarily to non-road and 

on-road diesel engines and primarily for reduction of particulate emissions. However, it reduces 

NOx by only 10-20%6.

Spark-Ignition (SI) Engine Emissions and Emission Control Technologies

SI engines fall into two major design categories. Four-stroke, rich-burn engines are designed to 

draw just the necessary amount of air to combust the fuel and little, if any, more. These engines 

operate with exhaust gas O2 content very near zero. The other category is lean-burn engines, 

which are designed to draw substantially more air than is required for combustion and operate 

with a high level of exhaust gas O2, typically 15%. Larger engines tend to be lean-burn, and 

 

4 U.S. EPA AP-42 Compilation of Air Pollution Emission Factors, Table 3.3-1.

5 South Coast Air Quality Management District, Staff Report for Proposed Amended BACT 

Guidelines, Part D, Non-Major Polluting Facilities, Regarding Emergency Compression –

Ignition (Diesel) Engines, April 2003.

6

http://www.epa.gov/region1/eco/diesel/retrofits.html#doc
Final Staff Report for Proposed Amended Rule 1110.2

10 May 2005

Table 6. U.S. EPA Nonroad Diesel Gaseous Emission Standards—

NOx or (NOx+NMHC)/NMHC/CO (g/Bhp-hr)

Engine 

Bhp

Tier 1 Tier 2 Tier 3 Tier 4

Interim

Tier 4

Final

50 to 

<75

1998

6.9

--

--

2004

(5.6)

--

3.7

2008

(3.5)

--

3.7

2012

(3.5)

3.7

75 to 

<100

1998

6.9

--

--

2004

(5.6)

--

3.7

2008

(3.5)

--

3.7

2012

2.6

0.14

3.7

2015

0.3

0.14

3.7

100 to 

<175

1997

6.9

--

--

2003

(4.9)

--

3.7

2007

(3.0)

--

3.7

2012

2.6

0.14

3.7

2015

0.3

0.14

3.7

175 to 

<300

1996

6.9

1.0

8.5

2003

(4.9)

--

2.6

2006

(3.0)

--

2.6

2011

1.5

0.14

2.6

2014

0.3

0.14

2.6

300 to 

<600

1996

6.9

1.0

8.5

2001

(4.8)

--

2.6

2005

(3.0)

--

2.6

2011

1.5

0.14

2.6

2014

0.3

0.14

2.6

600 to 

<750

1996

6.9

1.0

8.5

2002

(4.8)

--

2.6

2005

(3.0)

--

2.6

2011

1.5

0.14

2.6

2014

0.3

0.14

2.6

≥750 2000

6.9

1.0

8.5

2006

(4.8)

--

2.6

2011

2.6

0.3

2.6

2015

2.6

0.14

2.6

Note: ppmvd@15%O2 = g/Bhp-hr x (%EFFHHV/100) / 1.15 x F (F= 253 for NOx, 

415 for CO, 727 for VOC as methane)

smaller engines tend to be rich-burn. Typical emissions of NOx, CO and VOC from 

uncontrolled natural gas-fired engines are listed in Table 8. The emission factors in the table are 

based on U.S. EPA’s AP-427. Emissions produced by engines operating on fuels other than 

natural gas may differ from those listed in Table 8, but should be similar. NOx emissions from 

engines operating on landfill or digester gas should be significantly lower due to the thermal 

diluent effect of CO2 present in these types of waste gas.

 

7 U.S. EPA AP-42 Compilation of Air Pollution Emission Factors, Tables 3.2-2 and 3.2-3.
Final Staff Report for Proposed Amended Rule 1110.2

11 May 2005

Table 7. Emissions from Diesel Engine at Snow Summit Ski Resort (A/N 418235)

Concentration 

in Exhaust 

Gas, (ppmvd 

@ 15% O2)

Emission Rate, 

(g/Bhp-hr)

Tier 1 

Emission 

Standard, 

(g/Bhp-hr)

Apparent 

Reduction 

Based on 

Uncontrolled 

Level = Tier 1 

Less 20%, %

NOx 45 0.546 6.9 90

CO 5 0.037 8.5 99

VOC 49 0.21 1.0 74

Ammonia 0.6 -- -- --

In November 2001, CARB published a RACT/BARCT determination for stationary SI engines8. 

This determination, while not aggressive for CO or VOC, identified a number of NOx control 

technologies that are effective for stationary SI engines (Table 9) and recommended significant 

reductions in NOx (Table 10). Agricultural SI engines coming into the rule will generally have 

none of the emission controls listed in Tables 10 and 11. Lean-burn SI engines that are already 

subject to the rule will generally be equipped with low-emission combustion improvements, 

whereas rich-burn SI engines will have a three-way catalyst, also known as selective nonselective catalytic reduction (NSSNCR), which along with accurate control of the air/fuel ratio to 

near stoichiometric conditions, simultaneously reduces the three pollutants NOx, CO and VOC.

NOx, CO and VOC emission levels for stationary engines that are required by AQMD’s nonmajor source BACT guidelines are shown in Table 11. As indicated in the table, these limits are 

usually met using NS SNCR on rich-burn engines and SCR plus oxidation catalyst on lean-burn 

engines with low-NOx combustion modifications built into the engine by the manufacturer. Also 

shown in the table are apparent pollutant reductions achieved by these technologies based on the 

typical uncontrolled emission levels shown in Table 8.

 

8 California Environmental Protection Agency, Air Resources Board, Determination of 

Reasonably Available Control Technology and Best Available Retrofit Control Technology for 

Stationary Spark-Ignited Internal Combustion Engines, November 2001.
Final Staff Report for Proposed Amended Rule 1110.2

12 May 2005

Table 8. Uncontrolled Emissions from Natural Gas-Fired SI Engines *

Rich-Burn Lean-Burn

Lbs/MMBtuHHV Lbs/MMBtuHHV

NOx 2.21 4.08

CO 3.72 0.317

VOC 0.0296 0.118

ppmvd @ 15% O2 ppmvd @ 15% O2

NOx 590 1090

CO 1629 139

VOC 23 91

*g/Bhp-hr = lb/MMBtu x 1.15 / (%EFFHHV/100)

 ppmvd@15%O2 = lb/MMBtu x F (F = 267 for NOx, 438 for CO, 767 for VOC as 

methane)

Table 9. NOx Control Technologies for Stationary SI Engines

Technology NOx 

Reduction 

Capability, 

%

Comments

Ignition Timing Retard 15-30 Reduces efficiency by up to 5%

Pre-Stratified Charge (PSC) 80+ Not suitable for lean-burn engines

Low-Emission Combustion 

Modifications

80+ Pre-combustion chamber, leaning, ignition 

system improvement, turbocharger, air/fuel 

ratio control system. Retrofit kits are available 

for some engines.

Turbocharger with 

Aftercooler

3-35

Exhaust Gas Recirculation 

(EGR)

30

Non-selective Catalytic 

Reduction (NSCR)

90+ Three-way catalyst—reduces NOx, CO and 

VOC. Not suitable for lean-burn engines.

Selective Catalytic 

Reduction (SCR)

80+ Requires injection of urea or ammonia to 

react with NOx. Unreacted ammonia is 

emitted. Oxidation catalyst is normally 

included to reduce CO and VOC emissions.
Final Staff Report for Proposed Amended Rule 1110.2

13 May 2005

Table 10. CARB NOx RACT/BARCT Determination for Stationary SI Engines 

(ppmvd corrected to 15% O2)

Rich-Burn Lean-Burn

RACT 90% control or 50 ppm

NSCR, PSC for waste gases

80% control or 125 ppm

Low-Emission Combustion or SCR

BARCT 96% control or 25 ppm

NSCR, Inspection & Maintenance Program

Waste Gases: 90% control or 50 ppm

PSC

90% control or 65 ppm

Low-Emission Combustion Mod’s 

or SCR

Table 11. AQMD BACT Guidelines for Stationary Engines at 

Non-Major Polluting Facilities

PPMVD, corrected to 15% O2 Apparent Reduction 

by Control Technology Uncontrolled 

Emission

BACT

RichBurnLeanBurnRich-Burn 

(NSSNCR)*

LeanBurn 

(SCR + 

CatOx)

Rich-Burn 

(NSSNCR), 

%

LeanBurn 

(SCR + 

CatOx), 

%

NOx 590 1090 10 9 98+ 99+

CO 1629 136 69 33 95+ 75+

VOC 23 91 29 25 --- 73+

*Assuming engine is 30% efficient (HHV basis).

Other Technology Options

For some stationary agricultural engines affected by the proposed Rule 1110.2 amendment, other 

options may be better than adding control equipment to the existing engine to bring the engine 

into compliance with the rule. These include repowering the engine with a lower-emission 

engine or an electric motor. In an engine replacement, only the engine needs to be replaced, and 

the balance of system remains the same. Repowering is often the best option for diesel engines. 

While it is possible to bring a diesel engine into compliance with the proposed amended rule by 

adding retrofit emission control technologies, it may be less costly and more amenable to site 

conditions to repower. Repowering options include a SI engine equipped with a three-way 

catalyst and air/fuel ratio controller, or an electric motor. Repowering with a SI engine will 

require that the diesel fueling system also be replaced with a natural gas, propane or even 

gasoline fueling system. Repowering with an electric motor will require installation of electrical 

conduit from the nearest source of power with sufficient voltage and current capability. 
Final Staff Report for Proposed Amended Rule 1110.2

14 May 2005

PROPOSED AMENDMENTS

The basic purposes of the proposed amendments are to: make agricultural engines subject to the 

rule; make the rule consistent with state directives prohibiting the use of portable generators for 

supplying electric power to the grid or to a building, facility, stationary source or stationary 

equipment except in an emergency affecting grid stability; and clean up and simplify the rule by 

removing rule language that is no longer needed. References to “owner/operator” are replaced 

just by “operator” because operators are required to obtain permits and comply with the rules. A 

summary of the proposed amendments follows. They are discussed in order of importance rather 

than in subdivision order.

Exemptions – Subdivision (h)

This is the last subdivision in the rule, but it is useful to discuss it first so that it is understood up 

front what the proposed changes to the exemptions are. 

Agricultural Engines

In paragraph (h)(1), the exemption for all agricultural engines is removed and replaced by an 

exemption for orchard wind machines powered by an internal combustion engine. This type of 

equipment only needs to be used during subfreezing temperatures, which seldom occur in this 

District. When these conditions do occur, they are outside the smog season. For these reasons, 

they are proposed for exemption. Only 81 engine-driven wind machines were reported in the 

2004 AQMD Agricultural Equipment Survey. 

Emergency Standby Engines

The exemption language regarding the limitation on annual operation is changed from “less than 

200 hours” to “200 hours or less” to be consistent with Rule 1304(a)(4). Also, the definition of 

emergency standby engine is proposed to change, as discussed in a later section. Although the 

broad exemption for agricultural engines will be removed, emergency standby agricultural 

engines will still be exempt from the requirements of subdivision (d). 229 emergency standby 

engines were reported in the 2004 AQMD Agricultural Equipment Survey, more than any other 

type of engine.

Attainment Area Exemption

The current exemption in paragraph (i)(6) is for the eastern-most area of Riverside County that 

was not in the non-attainment portion of the county. The names of these areas have changed, 

and the proposed rule amendments in paragraph (h)(6) will incorporate these changes.

State-Registered Portable Engines

State law prohibits AQMD from regulating portable engines registered by the State for operation 

throughout California. The exemption in proposed amended paragraph (h)(9) is only revised to 

refer to the actual registration regulations in the CCR, rather than the authorizing regulation in 

the State Health and Safety Code.
Final Staff Report for Proposed Amended Rule 1110.2

15 May 2005

Nonroad Engines

Although nonroad engines are exempt from the emission limits of paragraph (d)(1), the 

exemption in paragraph (h)(10) is proposed for revision such that portable generators must still 

comply with a new usage requirement discussed in the next section of this report. 

Limited Agricultural Engine Exemption

In response to a request by the California Farm Bureau, a limited exemption is proposed in 

paragraph (h)(12) for agricultural engines. If an engine is so remote that it cannot be electrified, 

or if for some reason beyond the control the engine operator the project cannot qualify for the 

Agricultural Assistance Fund, then the operator could comply by installing a Tier 4 nonroad 

diesel engine by 2014. 

The USEPA Tier 4 emission standards are shown in Table 12. The nonmethane hydrocarbon 

(NMHC) and CO emission standards are considerably more stringent than Rule 1110.2. The 

NOx emission standards are also more stringent than Rule 1110.2, except for engines over 751 

hp that are not generator sets. The NOx + NMHC standard for engines < 75 hp is also less 

stringent than Rule 1110.2. The PM emission standards will likely require some kind of 

aftertreatment, such as a diesel particulate filter, in order to be met. The NOx standards that are 

0.5 grams/hp-hr or less will also likely require some aftertreatment such as SCR or a NOx trap.

Engines meetings these standards will begin to be available, depending on size, from 2011 to 

2012. 

Table 12 – USEPA Tier 4 Diesel Engine Emission Standards*

(grams per hp-hour)

Maximum 

Engine Power

Application PM NOx NMHC NOx + 

NMHC 

CO

50 < hp < 75 All 0.022 - - 3.5 3.7

75 ≤ hp < 174 All 0.015 0.30 0.14 3.7

174 ≤ hp ≤ 751 All 0.015 0.30 0.14 2.6

hp > 751 Generator Sets 0.022 0.50 0.14 2.6

hp > 751 All others 0.03 2.6 0.14 2.6

* Emission standards are from 40 CFR Part 1039, Section 1039.101, Table 1

Six out of 20 of the agricultural engines surveyed were 75 hp or less. None were larger than 465 

hp. It will not be known for a few more years if any of these engines will qualify for the 

exemption. Because the emission standards are somewhat higher than the usual BACT 

requirements for stationary engines, it is proposed that the Tier 4 engines be considered BACT 

for the engines that qualify for this limited exemption. 

Tier 4 emission standards are based on weighted-averages of many tests at different loads, 

whereas AQMD emission limits are based on a single test that could be at only one load. 

Because of this difference, it is proposed that Tier 4 engines be required to meet on an ongoing 

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Final Staff Report for Proposed Amended Rule 1110.2

16 May 2005

basis the “not-to-exceed” limits in 40 CFR 1039.101 paragraph (e), which are 25 to 50% higher 

than the Table 12 emission standards.

Requirements – Subdivision (d)

Alternative to Electrification

The original Rule 1110.2 required stationary engine owners to remove or electrify their engines 

before the year 2000, or control their emissions to meet the emission limits in the rule by 1994. 

In 1997, the rule was amended to allow owners who chose to electrify or remove the engine to 

keep them in service if the engines complied with more stringent emission limits equivalent to 

BACT. The compliance schedule and emission limits for this are in subdivision (e), Compliance 

rather than in subdivision (d), Requirements. 

The proposed amendment in subparagraph (d)(1)(A) moves the emission limits to the 

Requirements subdivision, and converts the limits to ppmvd, based on a typical engine 

mechanical efficiency of 30%. The original gram per brake horsepower-hour emission limits are 

difficult to enforce because of the difficulty in determining in the field engine work output in 

horsepower-hours. 

New Stationary Engines

A new subparagraph (d)(1)(D) is proposed to be added to the rule to accomplish two purposes. 

First, it notifies operators of new stationary engines that they are subject to Best Available 

Control Technology (BACT) of District Regulation XIII, which are more stringent than the 

emission limits of Rule 1110.2. Larger agricultural facilities that recently became subject to 

AQMD permitting requirements may not be aware of this requirement. Second, smaller 

agricultural facilities (below 50% of the Title V emission thresholds), whose engines are 

currently exempt from AQMD permits, will be required to comply with the emission limits of 

Table I of Rule 1110.2 when they install new engines. The Table I emission limits of 11 ppm 

NOx, 30 ppm NMHC, and 70 ppm CO (corrected to 15& O2 on a dry basis and averaged over 

15 minutes), are equivalent to BACT for stationary engines that other facilities must comply 

with. 

Portable Engines

To be consistent with state directives regarding the use of portable generators9 10, it is proposed 

in paragraph (d)(2)(B) that the amended rule prohibit use of portable engine generators to supply 

power to the grid or to a building, facility, stationary source or stationary equipment except in an 

emergency affecting grid stability or availability, during maintenance and repair operations or in 

remote locations where grid power is unavailable. The language used in the proposed 

amendment is identical to the same prohibition in the Statewide Portable Equipment Registration 

Program.

Portable diesel engines, which are not subject to the same stringent emission requirements as 

stationary engines, emit up to 70 times more NOx per MW-hr produced than the emission limits 

 

9 California Air Resources Board, Letter from Michael P. Kenny, February 21, 2001.

10 California Air Resources Board, Amendments to the Regulation for the Statewide Portable 

Equipment Registration Program (Resolution 04-8), 15-Day Comment Version, May 13, 2004.

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Final Staff Report for Proposed Amended Rule 1110.2

17 May 2005

on new stationary engines, and 440 times more than the emission limits on new central 

generating stations. 

This was especially a problem during the energy crisis of 2000-2001. Many facilities had 

voluntarily signed up with Southern California Edison (SCE) in the 1990s for interruptible 

electric schedules. In return for reduced electric rates, these facilities promised to reduce their 

electrical demand whenever the electric grid was short of power. For many years there were no 

interruptions, but starting in 2000 with the energy crisis SCE began requiring these facilities to 

reduce their electrical loads in accordance with their contracts. Many facilities were unprepared 

for this, and instead of actually reducing their operations to reduce electric loads, they purchased 

or rented portable diesel generators to provide electrical power during these interruptions. 

Portable diesels registered by the State are now prohibited from this. 

Staff is proposing, however, that portable generators that meet current BACT requirements for 

stationary non-emergency engines and meet all other requirements of Rule 1110.2 be exempted 

from this prohibition.

Compliance – Subdivision (e)

Removal of Obsolete Requirements

This subdivision of the current rule is mostly composed of obsolete compliance schedules whose 

final compliance dates have passed. All of that language is struck by the proposed amendments. 

Agricultural Stationary Engine Compliance Schedule

Subparagraph (e)(1)(A) will now provide a schedule for existing stationary agricultural engines 

to come into compliance with the rule, as non-agricultural engines have already done starting in 

1994. For most existing agricultural stationary engines, the schedule requires that an application 

for a permit to construct be submitted by September 1, 2007, construction to be initiated by 

March 30, 2008 (or 30 days after issue of the permit to construct if that date is later), and final 

compliance by July 1, 2008 (or 60 days after issue of the permit to construct, if that date is later). 

For Tier 2 and Tier 3 diesel engines and certified spark-ignition engines, these dates are all 

extended by 18 months. SB 700 requires implementation of BARCT rules by January 1, 2006. 

That implementation will begin with submittal of a notification of applicability to the Executive 

Officer.

New engines will have to comply upon installation, although they will also be subject to the even 

more stringent requirements of Best Available Control Technology, as required by AQMD’s 

New Source Review rules.

Monitoring, Testing and Recordkeeping – Subdivision (f)

Most of the proposed changes in this subdivision are simply to reorganize and clarify the 

requirements. For example, the title of the subdivision would be changed to indicate that it 

includes testing requirements, in addition to monitoring and recordkeeping. Significant changes 

are explained below. 

Source Testing for Stationary Engines

Proposed subparagraph (f)(1)(C) would be amended to allow relative accuracy tests required by 

Rule 218.1 or 40 CFR 75 Subpart E to satisfy the source testing requirement of this 
Final Staff Report for Proposed Amended Rule 1110.2

18 May 2005

subparagraph. Relative accuracy tests compare the emission results from a CEMS to the 

simultaneous emission results from a reference method. 

Operating Log

The current rule requires operators of stationary and portable engines to maintain a monthly 

operating log engine operation and fuel use. Proposed amended subparagraph (f)(1)(E) and 

paragraph (f)(2) would allow RECLAIM facilities to maintain a quarterly log for engines 

designated as process units on the facility permit. This is consistent with the recordkeeping 

requirements of the RECLAIM program.

Record Keeping for All Engines

The current rule, in subparagraph (f)(1)(B), only required CEMS data to be maintained for two 

years and made available for district inspection. Other records did not have to be maintained. 

That requirement is moved to new paragraph (f)(3) and extended to all the different types of 

records required for stationary and portable engines. In addition, the two year requirement is 

extended to five years, consistent with the requirement for Title V facilities.

Test Methods – Subdivision (g)

Only minor changes are proposed. One change will clarify that the VOC test method excludes 

both methane and ethane. Also, the EPA test methods will be deleted, leaving the preferable 

District Test Methods. For measurements of VOC emissions, in addition to District Method 

25.1, which is presently the only District method specified in the rule, staff is proposing that 

District Method 25.3 also be specified. The District requires that Method 25.3 be used when the 

VOC concentration is below 50 ppmvd.

Technology Assessment for PM2.5 - Subdivision (h)

This subdivision in the current rule is proposed to be deleted. It required the Executive Officer 

do a technology assessment for PM2.5 and report to the Board by December 30, 1999. This 

requirement was completed.

Definitions – Subdivision (c)

Agricultural Engines

A definition of Agricultural Stationary Engine is added as paragraph (c)(1).

Removed Definitions

Because parts of the rule whose compliance dates have passed are proposed for removal, two 

definitions are no longer needed. They are the definitions for Non-Road Engine and Rule 1110.1 

Emission Control Plan.

Facility

The definition is revised to be consistent with the definition in Rule 1302, which includes the 

definitions for the New Source Review regulation. 
Final Staff Report for Proposed Amended Rule 1110.2

19 May 2005

Stationary Engine

An engine is either stationary or portable. The current definition for stationary engine is not 

entirely consistent with the requirements in the definition for portable engine. The proposed 

modification will be consistent, because if an engine does not meet the requirements for a 

portable engine, it will be considered stationary.

EMISSION IMPACTS

The proposed amendments to Rule 1110.2 will have emission impacts on stationary, nonemergency engines used in agricultural operations. The proposed rescission of Rule 1110.1 will 

not result in emission impacts because it has been superceded by Rule 1110.2.

Stationary Non-Emergency Engines in Agricultural Operations

The emission reductions for the proposed amendments to Rule 1110.2 are shown in Table 13, 

and are estimated based on the difference between current uncontrolled emissions and the 

controlled emissions after rule requirements are fully implemented. The detailed calculations are 

shown in Appendix E. The emission reductions were based on reducing emissions by either 

electrifying an engine, replacing a diesel engine with an SI engine with a catalyst, or adding a 

catalyst and air/fuel ratio controller to the natural gas SI engines. For new SI engines that are 

Table 13. Expected Emission Reductions for PAR 1110.2 from 

Stationary, Non-Emergency Agricultural Engines

Engine Class Emissions (Tons/Year)

NOx VOC CO PM

Irrigation Pumps

Current 28.2 2.20 7.46 1.95

Reductions 28.0 2.16 5.86 1.93

Well/Water Pumps

Current 113 5.58 97.6 4.84

Reductions 112 5.55 92.4 4.80

Other Engines

Current 2.28 0.328 2.8 0.132

Reductions 2.22 0.277 0.78 0.107

Total Current 

Emissions

143.0 8.11 108.0 6.92

Total Emission 

Reductions 142.0 7.99 99.0 6.84

Total Emissions 

After Control 1.0 0.12 9.0 0.08
Final Staff Report for Proposed Amended Rule 1110.2

20 May 2005

replacing diesel engines, the emission limits are based on current BACT limits of 0.15 g/bhp-hr 

NOx, 0.15 g/bhp-hr VOC and 0.6 g/bhp-hr CO. 

Portable Engines

The proposed rule would prohibit the use of portable engine generators to supply power to the 

grid or to a building, facility, stationary source or stationary equipment except in an emergency 

affecting grid stability or availability, during maintenance and repair operations or in remote 

locations where grid power is unavailable. It isn’t known how many portable engines are 

currently doing what would become prohibited under the proposed amendment, probably very 

few or none. But if an energy crisis happens again, there could suddenly be a demand to put 

portable engines to this use. One pre-2000 diesel engine rated at 1000 hp, can emit 160 pounds 

of NOx in one six-hour curtailment. Because these electrical interruptions are often during hot

summer days when electricity is short, they coincide with the smoggiest conditions in AQMD. 

The other amendments affecting portable engines will have no emission impacts.

COST-EFFECTIVENESS

State Law Requirements

State law [H&SC 40724] requires local air districts to ensure that the cost-effectiveness of best 

available retrofit control technology (BARCT) for internal combustion engines used in 

agricultural applications is similar to the cost-effectiveness of BARCT for other internal 

combustion engines subject to regulation by a district or the state board. Cost-effectiveness of 

BARCT for engines used in agricultural applications is also to be compared to a list of available 

and proposed control measures in the district’s Air Quality Management Plan (AQMP) arranged 

in order of cost-effectiveness [H&SC 40922]. Also, H&SC 40920.6 requires calculation of costeffectiveness and incremental cost-effectiveness for all new requirements.

Cost-Effectiveness Calculations

Cost-effectiveness calculations were performed for cases that are representative of engines that 

will be affected by the proposed rule amendment. For each case, the available technology 

options for meeting the rule requirements were considered. The costs of modifying or replacing 

the engines can be largely offset by funding that is available from the Carl Moyer Memorial 

program (CMP) and the state Agricultural Assistance Program (AAP) (AB923). This 

Agricultural Assistance Program is the only one of its type that provides state funding for 

emission reductions required by a local air district rule. A full explanation of the program is in 

Appendix B. These funds may be used to compensate the engine owner for engine modification 

or replacement costs to the extent that these costs exceed the cost that would be incurred in 

having the existing engine rebuilt. Costs of complying with the rule both with and without AAP 

funding are shown in Table 14. The cost-effectiveness results, also with and without AAP 

funding, are shown in Table 15. The detailed calculations and assumptions are provided in 

Appendix A.

From the AQMD survey of agricultural facilities previously discussed, the basis of the 

calculation was a facility with two 175 hp engines. This represents the average engine size and 

number of engines per facility found in the survey. Both diesel and SI engines were considered. 

Although it is likely that most agricultural engines are uncertified (“Tier 0”), it is possible that 
Final Staff Report for Proposed Amended Rule 1110.2

21 May 2005

some diesel engines are Tier 1, Tier 2, or even Tier 3 and that some Tier 1 SI agricultural engines 

may have been installed. Using an operational scenario that is considered in the CMP 

guidelines11 to be typical of agricultural engine operation, the calculations were based on 2000 

hours per year operation per engine and operation at 65% of the engine’s full capacity.

Costs that were considered in the calculations included the cost of replacement or improvement 

of the engines to meet the emission limits in the rule, any resulting increase in annual operating 

and maintenance expense and the cost of source testing every three years as required by the rule. 

Cost-effectiveness calculations followed the discounted cash flow methodology in AQMD’s 

BACT Guidelines. For each technology option, the present value of the ten-year cost of the

technology and the tons of NOx and VOC reduced by the technology over the ten-year period 

were calculated. From these results, the cost per ton of NOx + VOC reduced was calculated. As 

seen in the third column of Table 15, technology options having cost-effectiveness less than 

$19,000 per ton of NOx+VOC reduced are available for all cases considered.

The amount of AAP funding available for a given project is limited by a maximum costeffectiveness of $13,600 per avoided ton of NOx and VOC, and PM multiplied by ten. In 

calculating cost-effectiveness for comparison to this figure, the annualized value of the funding 

is considered relative to the annual tons of avoided pollution. The last column of Table 15 shows 

the cost-effectiveness of each technology option in dollars per ton of NOx+VOC reduced based 

on the net cost to the engine owner after receipt of AAP funds . On this basis, technology 

options having cost-effectiveness less than $10,000 per ton of NOx+VOC are available for all 

cases considered. Electrification of diesel engines results in a net savings to the agricultural 

facility.

Cost-Effectiveness Comparisons

The cost-effectiveness of the proposed rule amendments for agricultural engines, in terms of 

costs to the engine owner, will be less than the cost-effectiveness of the current rule for nonagricultural engines. This is because the agricultural facilities are required to meet the same 

requirements as the non-agricultural facilities but only the agricultural facilities can qualify for 

state funding to reduce the cost to the owner.

State law [H&SC 40724] requires local air districts to compare the cost-effectiveness of any 

proposed rule affecting agricultural engines to a list of available and proposed control measures 

in the AQMP arranged in order of cost-effectiveness [H&SC 40922].

Table 16 and Table 17 provide a listing of the control measures from the AQMP that have 

available cost information for stationary and mobile source measures, respectively. Two 

methods are used to calculate the cost-effectiveness of the mobile source measures. The CARB 

transmitted the cost-effectiveness values for the mobile source measures based on incremental 

cost analyses, published reports and other internal methods. However, the District uses the 

Discounted Cash Flow method in its calculations, as it has since the 1987 AQMP. The 

Discounted Cash Flow method is more versatile in analyzing complex financial cash flows and is 

the most widely used cost methodology by major businesses. 

 

11 The Carl Moyer Memorial Air Quality Standards Attainment Program Guidelines, Chapter 6, 

Stationary Agricultural Irrigation Pump Engines.
Final Staff Report for Proposed Amended Rule 1110.2

22 May 2005

Table 14. Cost of Bringing Agricultural Engines into Compliance with PAR 1110.2 ($K)

(Facility with two 175 hp engines operated 2000 hrs/yr at 65% capacity

Case Control Technology

Installed 

Cost

Incremental

Annual 

O&M

Annual 

Source 

Testing

AAP 

Incentive

Net Cost with AAP

Incentive

Installed

Cost

Total 

Annual

Diesel Engine,

Tier 0

SI Engine + NSCR 84.9 7.3 2.0 78.4 6.5 9.3

Electric 136.9 -8.3 0.0 130.4 6.5 -8.3*

Tier 1 + SCR 120.9 46.7 2.0 114.4 6.5 48.7

Diesel Engine, 

Tier 1

SI Engine + NSCR 84.9 7.3 2.0 78.4 6.5 9.3

Electric 136.9 -8.3 0.0 130.4 6.5 -8.3*

SCR 73.6 45.3 2.0 67.1 6.5 47.3

Diesel Engine,

Tier 2

SI Engine + NSCR 84.9 7.3 2.0 78.4 6.5 9.3

Electric 136.9 -8.3 0.0 130.4 6.5 -8.3*

SCR 73.6 45.3 2.0 67.1 6.5 47.3

Diesel Engine,

Tier 3

SI Engine + NSCR 84.9 7.3 2.0 78.4 6.5 9.3

Electric 136.9 -8.3 0.0 130.4 6.5 -8.3*

SCR 73.6 45.3 2.0 67.1 6.5 47.3

SI Engine, 

Tier 0

NSCR 51.3 15.0 2.0 31.8 19.5 17.0

Electric 147.7 9.6 0.0 128.2 19.5 9.6

New Engine + NSCR 84.9 15.0 2.0 65.4 19.5 17.0

SI Engine, 

Tier 1

NSCR 51.3 15.0 2.0 31.8 19.5 17.0

Electric 147.7 9.6 0.0 128.2 19.5 9.6

*A negative cost means that the facility owner will have a net savings rather than a cost.

Definitions:

$K = thousands of dollars

Tier 0 = Uncertified Engine (no emission controls)

Tier 1, 2, 3 Engine = Engine certified to meet U.S. EPA emission standards

SI Engine = Spark Ignition Engine

NSCR = Non-Selective Catalytic Reduction, a method of reducing NOx, CO and VOC 

emissions

SCR = Selective Catalytic Reduction, a method of reducing NOx emissions

O&M = Operating and Maintenance Cost
Final Staff Report for Proposed Amended Rule 1110.2

23 May 2005

Table 15. Cost-Effectiveness of PAR 1110.2 for Agricultural Engines

($K per Ton NOx+VOC)

Case Control Technology

CostEffectivenessCost-Effectiveness with AAP 

Incentive

Diesel Engine,

Tier 0

SI Engine + NSCR 2.2 1.2

Electric 0.9 -0.8*

Tier 1 + SCR 7.2 5.6

Diesel Engine, 

Tier 1

SI Engine + NSCR 4.3 2.2

Electric 1.7 -1.6*

SCR 15.2 13.0

Diesel Engine,

Tier 2

SI Engine + NSCR 7.1 3.7

Electric 2.7 -2.6*

SCR 26.3 22.5

Diesel Engine,

Tier 3

SI Engine + NSCR 12.2 6.4

Electric 4.5 -4.2*

SCR 43.8 37.6

SI Engine, 

Tier 0

NSCR 5.1 4.2

Electric 5.3 2.3

New Engine + NSCR 5.5 3.9

SI Engine, 

Tier 1

NSCR 18.6 15.5

Electric 15.7 6.9

*A negative cost-effectiveness means that the facility owner will have a net savings 

rather than a cost.

Definitions:

$K = thousands of dollars

Tier 0 = Uncertified Engine (no emission controls)

Tier 1, 2, 3 Engine = Engine certified to meet U.S. EPA emission standards

SI Engine = Spark Ignition Engine

NSCR = Non-Selective Catalytic Reduction, a method of reducing NOx, CO and VOC 

emissions

SCR = Selective Catalytic Reduction, a method of reducing NOx emissions
Final Staff Report for Proposed Amended Rule 1110.2

24 May 2005

Table 16. Cost-Effectiveness Ranking of District’s Stationary Source Control Measures 

a 

Measure 

Number 

Description Dollars

per Ton 

Ranking by 

Cost

-Effectiveness 

BCM-08 Further Emission Reductions from Aggregate 

and Cement Manufacturing Operations 

$700 1 

WST-01 Emission Reductions from Livestock Waste 

(PR1127) 

$2,000 -

$7,000 

2 

CMB-09 Emission Reductions from Petroleum Fluid 

Catalytic Cracking Units (PR1105.1) 

$3,500 -

$11,500 

3 

CMB-10 Additional Reductions for NOx RECALIM $5,000 4 

MSC-05 Truck Stop Electrification $5,000 4 

WST-02 Emission Reductions from Composting 

(R1133, 1133.1, 1133.2) 

b $10,000 

c 5 

CTS-10 Miscellaneous Industrial Coatings and 

Solvents 

< $13,500 6 

FUG-05 Emission Reductions from Fugitive Sources < $13,500 7 

PRC-07 Industrial Process Operations < $13,500 8 

PRC-03 Emission Reductions from Restaurant 

Operations 

$14,500 9 

CTS-07 Further Emission Reductions from 

Architectural Coatings (R1113) 

< $20,000 10 

a 

The cost-effectiveness values of these measures are based on the Discounted Cash Flow 

methodology and four percent real interest rate. 

b 

Control Measure WST-02 was adopted January 10, 2003 as Rule 1133 - Composting and 

Related Operations – General Administrative Requirements, Rule 1133.1 Chipping and 

Grinding Activities, and Rule 1133.2 - Emission Reduction From Co-Composting Operations. 

c 

Cost-effectiveness based on VOC and NH3 reductions combined. 
Final Staff Report for Proposed Amended Rule 1110.2

25 May 2005

Table 17. Cost-Effectiveness Ranking of State and Federal Control Measures* 

Measure 

Number 

Description Dollars

per Ton 

Ranking by 

Cost

-Effectiveness 

OFF-RD LSI1 

Set Lower Emission Standards for New Off-Road 

Gas Engines [Spark-Ignition Engines 25 hp and 

Greater] 400 

1 

SMALL 

OFF-RD-2 

Set Lower Emission Standards for New NonHandheld Lawn and Garden Equipment –

Lawnmowers [Spark-Ignition Engines Under 25 

hp] 900 

2 

SMALL 

OFF-RD-1 

Set Lower Emission Standards for New Handheld 

Lawn and Garden Equipment –Weed Trimmers, 

Leaf Blowers, and Chain Saws [Spark-Ignition 

Engines Under 25 hp] 1,250 

3 

MARINE-2 

Pursue Approaches to Clean Up the Existing 

Harbor Craft Fleet - Cleaner Engines and Fuels 1,300 

4 

OFF-RD CI-1 

Set Lower Emission Standards for New Off-Road 

Engines [Compression-Ignition Engines] 1,500 

5 

MARINE-1 Set More Stringent Emission Standards for New 

Harbor Craft and Ocean-Going Ships 3,100 

6 

AIRPORT-1 

Pursue Approaches to Reduce Emissions from Jet 

Aircraft 3,500 

7 

MARINE-4 

Pursue Approaches to Reduce Land-Based 

Emissions at Ports 

3,700-

36,400 

8 

ON-RD 

HVY-DUTY3 Pursue Approaches to Clean Up the Existing and 

New Truck/Bus Fleet 3,700 

9 

FVR-1 

Increase Recovery of Fuel Vapors from 

Aboveground Storage Tanks 4,000 

10 

FVR-3 

Reduce Fuel Permeation Through Gasoline 

Dispenser Hoses 4,000 

10 

CONS-1 Set New Consumer Products Limits for 2006 4,500 

11 
Final Staff Report for Proposed Amended Rule 1110.2

26 May 2005

Table 17. Cost-Effectiveness Ranking of State and Federal Control Measures* (Cont.)

Measure 

Number 

Description Dollars/Ton Ranking by 

CostEffectiveness 

CONS-2 

Set New Consumer Products Limits for 

2008-2010 4,500 

11 

MARINE-3 

Pursue Approaches to Clean Up the Existing 

Ocean-Going Ship Fleet 6,000-9,400 

12 

LT/MEDDUTY-2 Improve Smog Check to Reduce Emissions 

from Existing Passenger and Cargo Vehicles 7,500 

13 

ON-RD 

HVYDUTY-2 Capture and Control Vapors from Gasoline 

Cargo Tankers 7,500 

13 

OFF-RD 

LSI-2 

Clean Up Existing Off-Road Gas Equipment 

Through Retrofit Controls [Spark-Ignition 

Engines 25 hp and Greater] 

7,500 13 

OFF-RD 

LSI-3 

Require New Forklift Purchases and Forklift 

Rentals to be Electric -- Lift Capacity 

<8,000lbs] 

7,500 13 

FVR-2 

Recover Fuel Vapors from Gasoline 

Dispensing at Marinas 8,000 

14 

ON-RD 

HVYDUTY-1 

Augment Truck and Bus Highway 

Inspections with Community-Based 

Inspections 8,800 

15 

OFF-RD CI2 

Pursue Approaches to Clean Up the Existing 

Off-Road Equipment Fleet [Compression 

Ignition Engines] 18,000 

16 

OFF-RD CI3 

Implement Registration and Inspection 

Program for Existing Heavy-Duty Off-Road 

Equipment to Detect Excess Emissions 

[Compression-Ignition Engines] 18,000 

16 

LT/MEDDUTY-1 

Replace or Upgrade Emission Control 

Systems on Existing Passenger Vehicles –

Pilot Program 19,000 

17 

*Cost-effectiveness calculated by CARB. 

The cost-effectiveness for stationary source measures ranges from $700 to $20,000 per ton of 

pollutant reduced, and the cost-effectiveness for mobile source measures ranges from $400 to 

$19,000 per ton of pollutant reduced. The overall range is thus $400-$20,000 per ton. As shown 

in Table 15, technologies are available to meet the requirements of the proposed amended rule 

that have cost-effectiveness less than $20,000 per ton of NOx + VOC reduced and, for the most 
Final Staff Report for Proposed Amended Rule 1110.2

27 May 2005

part, assuming that most agricultural engines subject to PAR 1110.2 are Tier 0 engines, the costeffectiveness is expected to range from a savings up to $5,600 per ton of NOx+VOC reduced.. 

Incremental Cost-Effectiveness

For cases in which an emission control technology is being proposed but a less costly but less 

effective technology is available, the incremental cost-effectiveness of the proposed technology 

versus the less costly technology has to be considered, according to state law. The incremental 

cost-effectiveness is the incremental cost divided by the incremental amount of pollutant 

reduction achieved by the proposed technology relative to the less costly/less effective 

technology.

It is unusual with this rule that the lowest-emission alternative, electrification, is also the lowestcost alternative. For this option, there is no incremental cost; and in many cases there is an 

incremental savings. The following incremental cost-effectiveness analysis focuses on the 

lowest-cost option of those found to be cost-effective for each case, excluding electrification. 

Excluding electrification allows examination of the situation in which electrification is not 

practical, for example in an extremely rural area where the cost of extending the electrical lines 

far exceeds the amount estimated. It is for this situation that the incremental cost-effectiveness 

relative to the next most cost-effective option would be significant. Lower-cost, less-effective 

technologies were determined to be available for two cases.

 For stationary agricultural diesel engines that are uncertified or certified to Tier 1 or Tier 

2, the lowest-cost non-electric option for meeting the proposed amended rule where 

electrification is not practical would be to replace the engine with an SI engine equipped 

with SNCR. However, a lower-cost option, although not meeting the proposed amended 

rule requirements, would be to replace the engine with a Tier 3 diesel engine.

 For stationary agricultural uncertified or Tier 1 SI engines, the lowest-cost non-electric 

option for meeting the proposed amended rule is to add an NSSNCR system. However, 

lower-cost options for an uncertified engine would be to modify the engine with lowemission combustion modifications or a pre-stratified charge system, and a lower-cost 

option for either an uncertified engine or a Tier 1 engine would be to replace the engine 

with a Tier 2 engine.

The results of the incremental cost-effectiveness calculations are shown in Table 18, and the 

detailed calculations are shown in Appendix A. Criteria for acceptable incremental cost

-effectiveness are much higher than those for basic cost-effectiveness. For BACT costeffectiveness analyses, the incremental cost-effectiveness criteria are three times the basic costeffectiveness criteria. Applying a similar convention in this case, the incremental cost

-effectiveness results are considered to be acceptable.
Final Staff Report for Proposed Amended Rule 1110.2

28 May 2005

Table 18. Results of Incremental Cost-Effectiveness Evaluation

Case Lowest-Cost

Non-Electric

Cost-Effective 

Technology

Next Most 

Effective 

Technology

Incremental Cost

-Effectiveness, 

$K/ton NOx+VOC

Stationary Agricultural 

Uncertified, Tier 1 or 

Tier 2 Diesel Engine

SI Engine + 

NSCR

Replacement with 

Tier 3 Diesel Engine $48.2

Stationary Agricultural 

Uncertified or Tier 1 

SI Engine 

NSCR

NSCR

NSCR

Low-Emission 

Combustion 

Modifications

Pre-Stratified 

Charge

Tier 2 Engine

$46.2

$40.4

$14.3

CALIFORNIA ENVIRONMENTAL QUALITY ACT (CEQA)

AQMD prepared a Draft Environmental Assessment (Draft EA) for the proposed amendments to 

Rule 1110.2 and the rescinding of Rule 1110.1, which was released for public review and 

comment on March 18, 2005. The Draft EA concluded that any potential adverse environmental 

impacts were not significant. Therefore, the public is provided a 30-day public comment and 

review period ending April 19, 2005. The Draft EA is available at AQMD Headquarters, by 

calling the AQMD Public Information Center at (909) 396-2039, or by accessing AQMD’s 

CEQA website at: www.aqmd.gov/ceqa.

SOCIOECONOMIC ASSESSMENT

Affected Facilities

PAR 1110.2 has administrative amendments that will affect approximately 2,724 engines at 673

facilities of all industries that have non-emergency stationary and portable internal combustion 

engines (ICEs) over 50 brake horsepower. However, costs will only be incurred by the 

agricultural facilities. An agricultural operations survey mailed to 1,925 agricultural facilities in 

April and June 2004 had 885 surveys returned (46% response rate). Based on the surveys 

returned, there were 12 agricultural facilities with 20 internal combustion engines. However, the 

number of agricultural facilities and internal combustion engines was doubled to reflect the 

survey response rate, with the assumption that survey responders are representative of those that 

did not respond to the survey. Hence an estimated 24 agricultural facilities and 40 internal 

combustion engines will be brought into Rule 1110.2 for the first time.

These agricultural facilities belong to the industries of fruit and tree nut production (Standard 

Industrial Classification (SIC) 0179 or North American Industry Classification System (NAICS)

111336); ornamental floriculture (SIC 0181 or NAICS 111422) and nursery products (SIC 0181 

or NAICS 111421); general farms (primarily crop farms) (SIC 0191 or NAICS 111998); and 
Final Staff Report for Proposed Amended Rule 1110.2

29 May 2005

dairy farms (SIC 0241 or NAICS 112120). Although there are agricultural facilities in all four 

counties, only an estimated 24 facilities in three of the four counties will be affected by proposed 

amendments to Rule 1110.2. These include two facilities in Orange County (8%), 12 facilities in 

Riverside County (50%), and 10 facilities in San Bernardino County (42%).

The 2004 Dun and Bradstreet data has employment and gross revenue information on seven of 

the 12 agricultural facilities that submitted survey data. Based on AQMD’s definition of a small 

business, two of these seven facilities would be classified as small businesses. Based on SBA’s 

and CAAA’s definitions of a small business, four facilities would be small businesses. For both 

definitions, these are the same four facilities.

Compliance Costs

Operators of existing stationary agricultural engines would comply with the proposed 

amendments of Rule 1110.2 by replacing their engines with a controlled spark ignition (SI) 

engine and non-selective catalytic reduction system (NSCR) or an electric motor, or by adding 

an NSCR to an existing SI engine.

The full cost of capital equipment and the difference between proposed and existing operating 

and maintenance costs are used to reflect the additional costs or savings associated with the 

proposed amendments. Capital equipment costs range from $21,400 - $181,900, depending on 

engine type, manufacture year (pre/post 1996) and horsepower. Net annual operating and 

maintenance costs range from a savings of $22,100 to a cost of $8,300 depending on engine type, 

manufacture year (pre/post 1996) and horsepower. Savings are expected to result from 

electrification for existing diesel engines even based on summer on-peak demand rate schedules 

while additional costs will be incurred through operating and maintenance costs associated with 

NSCR and higher energy costs converting from natural gas to electrification.12 Capital 

equipment costs drop significantly when offset by outside funding, with net costs ranging from 

$2,300 - $12,200, depending on engine type, manufacture year and horsepower. Funding 

through the Carl Moyer Program and Agricultural Assistance Program (AAP) can be used for 

agricultural sources, and in the case of AAP funding, to satisfy existing regulatory requirements. 

It is assumed that operators of these engines would take the opportunity to apply for these funds 

to reduce the compliance costs of the proposed amendments to Rule 1110.2. Table 19 shows 

control technology and annual operating and maintenance costs for various types of engines, and 

indicates control equipment costs with and without outside funding. 

 

12 Electrification costs from diesel are based on the proposed Southern California Edison TOU-PA-ICE rate schedule, a timeweighted demand rate of $.0592/kWh plus monthly charges of $50.51 per meter charge, $2.89/kWh demand charge and 

$1.09/kWh summer on-peak demand charge. Electrification costs from a spark ignition engine are based on the Southern 

California Edison TOU-PA-B rate schedule, a time-weighted demand rate of $.0656/kWh plus monthly charges of $50.51 per 

meter charge, $4.18/kWh demand charge and $8.25/kWh summer on-peak demand charge.
Final Staff Report for Proposed Amended Rule 1110.2

30 May 2005

Table 19−Control Technology and Operating/Maintenance Costs Per Engine*

Proposed Control 

Technology

Control Equipment Costs 

Without Funding

Control Equipment

Costs with Funding

Annual O&M Costs

Diesel to SI Engine/NSCR

$27,100 -

$45,300 $3,000 - $12,200** $5,900 - $7,000 cost

Diesel to Electrification

$30,900 -

$181,900 $2,300 - $6,200

$1,000 - $22,100 

savings

SI Engine and NSCR

$21,400 -

$44,000 $6,300 - $9,000 $7,400 - $8,300 cost

Nat. Gas to Electrification

$59,400 -

$101,400 $8,900 - $12,000 $1,400 - $2,700 cost

*Based on information from control equipment manufacturers.

**Higher range of cost based on engine replacement of existing engine purchased in 2004.

Based on an assumption of a ten year equipment life and a 4% real interest rate, the annualized 

compliance cost for all agricultural sources is $0.316 million. Assuming the availability of 

outside funding, the total annualized cost for all agricultural sources would be reduced to $0.040 

million. With outside funding, the dairy farm industry would incur a savings overall in 

annualized compliance costs due to the savings in energy costs in converting from diesel to 

electrification. Annualized compliance costs by affected industry, with and without outside 

funding, are shown in Table 20.

Table 20−Annualized Compliance Costs for PAR 1110.2 Agricultural Sources by Industry

Without Funding With Outside Funding

Industry Annual Cost of 

Compliance

% of Total 

Cost

Annual Cost of 

Compliance

% of Total 

Cost

Fruit and Tree Nut Production $20,723 6.5% $17,057 42.7%

Ornamental Floriculture & Nursery 24,950 7.9 7,853 19.7

General Farms, Crop Production 135,615 42.9 17,486 43.8

Dairy Farms $134,954 42.7% -$2,462 -6.2%

TOTAL $316,242 100.0% $39,935 100.0%

The proposed amendments also include administrative changes such as 

monitoring/recordkeeping and source testing requirements for all stationary and portable 

engines, which do not have significant socioeconomic costs. Estimated permit processing fees 

for agricultural sources affected by Rule 1110.2 are $0.015 million, annual operating fees are 

$0.008 million, emissions fees are $0.006 million and Title V processing fees are $0.0009 

million, for a total of $0.031 million.

Potential Impact of Fees on Agricultural Sources

The resolution for proposed amendments to Rule 1110.2 recommends that all agricultural 

sources be brought into the AQMD permitting system to ensure rule compliance. Preliminary 

findings show that bringing agricultural sources that are less than half of the major source 

emissions threshold into the permitting system is no more burdensome than for other industrial 

sectors under regulation.
Final Staff Report for Proposed Amended Rule 1110.2

31 May 2005

Rule 1110.2 (Emissions from Gaseous- and Liquid-Fueled Internal Combustion Engines), Rule 

461 (Gasoline Transfer and Dispensing) and Rule 403 (Fugitive Dust) are being amended in June 

2005 to incorporate provisions of SB 700 and require agricultural sources to comply with 

existing AQMD regulations. For Rule 1110.2 and Rule 461, AQMD staff has determined that it 

is necessary to bring all agricultural sources into the AQMD permitting system in order to ensure 

rule compliance. SB 700 requires that in order to permit agricultural sources that are under half 

of the major source emissions threshold, findings need to show that it is no more of an economic 

burden to permit agricultural sources than other industries regulated by AQMD. Analyzing the 

impact of regulatory fees is also important to consider given that the agricultural sector differs 

from other industrial sectors since some of its markets are regulated and it may have limitations 

in passing on the additional costs of production to consumers.

In April and June 2004 AQMD sent an agricultural operations survey to 1,925 agricultural 

facilities. Of the 885 surveys returned (46% response rate), 473 surveys reported having 

cows/heifers/calves or various types of equipment (internal combustion engines, boilers/heaters, 

gasoline dispensing/storage equipment, grain conveyor/silo, paint spray equipment or 

degreasers). The 2004 Dun and Bradstreet data has employment and gross revenue information 

on 192 (41%) out of the 473 agricultural facilities reporting animals or equipment. Based on 

AQMD’s definition of a small business, 114 facilities would be classified as small businesses. 

Based on SBA’s definition of a small business, 124 facilities would be classified as small 

businesses.

These agricultural facilities belong to the industries of crop production (SIC 01 or NAICS 111) 

and animal production (SIC 02 or NAICS 112). Dominant agricultural industries include the 

dairy cattle and milk production industry (NAICS 112120), which comprises 59% of the 

agricultural facilities surveyed. Of these 473 agricultural facilities, there are 7 in Los Angeles 

County (1%), 12 in Orange County (3%), 222 in Riverside County (47%), and 232 in San 

Bernardino County (49%).

Agricultural facilities would need to pay permit processing and annual renewal fees on 

equipment such as internal combustion engines, gasoline storage tanks, and confined animal

operations. Permit processing fees would be $380 per piece of equipment of confined animal 

operation (based on Rule 312 fee structure that expires on June 30, 2005 and the SB 700 

requirement that agricultural facilities undergo permitting by that date) and annual renewal fees 

of $208 per piece of equipment or confined animal operation. Some animal operations would 

not need to pay permit and annual renewal fees depending on the confined animal operation 

guidelines to be released by CARB. However, for the purpose of this analysis, it is assumed that 

dairies with 700 or more cows13 and all poultry operations would be required to pay permit and 

annual renewal fees. There is also one Title V facility that would need to pay a permit 

processing fee of $923 and permit processing and annual renewal fees for individual pieces of 

equipment or for any confined animal operation on the facility. Agricultural facilities whose 

total NOx, VOC and CO emissions were under 4 tons per year would be required to pay a flat 

emissions fee of $77. Agricultural facilities emitting greater than 4 tons per year of NOx, VOC 

and CO emissions would be required to pay per ton emissions fees of $215 per ton of NOx, $367 

 

13 Based on 2002 data from Santa Ana Regional Water Quality Control Board.
Final Staff Report for Proposed Amended Rule 1110.2

32 May 2005

per ton of VOC, and $4 per ton of CO (greater than 100 tons). Animal operations would also 

pay emissions fees based on the number of animals on the facility, using the approved animal 

emissions factors. 

Based upon data from the agricultural operations survey and from Dun and Bradstreet, it is 

estimated that permit processing fees would be $0.093 million, annual renewal fees would be 

$0.072 million, emissions fees would be $0.006 million and Title V fees would be $0.0009 

million, with total fees estimated at $0.173 million. A ratio of estimated AQMD fees to output 

was determined using data from REMI Policy Insight, the regional economic modeling software 

used by AQMD. It is estimated that the agricultural sector will pay 0.01% of their output on 

AQMD fees. In general, other regulated industrial sectors pay between 0.01% and 0.07% of 

their output towards fees14, making the percentage for the agricultural sector within this range. 

The analysis is unable to fully estimate emissions fees for agricultural facilities as emissions will 

not be reported until 2006. This preliminary assessment does indicate that the currently 

proposed permit processing and annual operating fees to be charged to all agricultural sources 

would be in line with fees paid by other regulated industries as a proportion of total output 

generated by these industries.

COMPARATIVE ANALYSIS

As required by Health and Safety Code Section 40727.2, the purpose of this analysis is to 

identify and compare any other AQMD or federal regulations that apply to the same equipment 

or source type. Federal Title I and state Clean Air Air (CAA) New Source Review (NSR)

requirements, as well as SB700 generally do not address air toxics. However, federal CAA's 

Title III requirements and state ATCM (AB1807) requirements may apply to agricultural 

sources.

Existing Federal Requirements

On June 15, 2004, the U.S. EPA issued final requirements to reduce toxic air emissions 

(formaldehyde, acrolein, methanol, and acetaldehyde) for stationary engines, which are 

contained in the National Emission Standard for Hazardous Air Pollutants for Stationary 

Reciprocating Internal Combustion Engines (RICE NESHAP). The RICE NESHAP establishes

requirements for large (> 500 horsepower) stationary engines, both CI and SI, located at major 

sources of hazardous air pollutants.

The RICE NESHAP affects a few California facilities that are also subject to PAR 1110.2. The 

RICE NESHAP requires installation of oxidation catalysts to reduce hazardous air pollutants 

(aldehydes) and CO and also specifies recordkeeping, monitoring, and testing requirements. 

Table 21 provides a summary of the key elements of PAR 1110.2 as compared to similar 

sections of the RICE NESHAP that are applicable to CI and SI engines.

 

14 Based on June 2005 Regulation III—Fees socioeconomic analysis.
Final Staff Report for Proposed Amended Rule 1110.2

33 May 2005

Table 21. Comparison of Key Elements of the federal RICE NESHAP

and PAR 1110.2 that Are Applicable to SI and CI Engines 

General 

Requirements

Reciprocating Internal 

Combustion Engine (RICE) 

NESHAP

PAR 1110.2

Applicability Applies to stationary CI and SI

engines above 500 HP located at 

a major source15 throughout the 

U.S.

Applies to stationary and 

portable CI and SI engines above 

50 hp located in the SCAQMD

Targeted Pollutants Formaldehyde and CO16 NOx, VOCs, and CO 

Exemptions New or reconstructed17 RICE 

meeting any of the following 

criteria have no requirements 

except for an initial notification 

(within 120 days of publication of 

final rule in Federal Register)

 Emergency power 

 Those that operate < 50 

hrs/yr

 Uses digester or landfill gas 

The following existing18 RICE:

 SI two-stroke, lean-burn 

(2SLB)

 SI four-stroke, lean-burn 

(4SLB)

 CI

 Emergency

 Those that operate

 < 50 hrs/yr

 Those that use digester or 

landfill gas

RICE being tested at test 

cells/stands.

Portable engines registered under 

the state registration program.

Emergency standby engines 

which operate  200 hours per 

year and engines powering 

orchard wind machines.

Engines used for: fire-fighting 

and flood control; research and 

testing; performance and testing 

verification; powering other 

engines or gas turbines during 

start-ups.

Engines operating on San 

Clemente Island and in the 

Eastern portion of Riverside 

County, outside the 

nonattainment areas. 

Supplemental engines which 

only operate from November 1 to 

April 15 for the manufacture of 

snow and/or operation of ski lifts.

 

15 A major source of Hazardous Air Pollutants (HAP) is a plant site that emits or has the potential 

to emit any single HAP at a rate of 10 tons or more per year or any combination of HAP at a rate 

of 25 tons or more per year. Although numerous HAP may be emitted from engines, 

formaldehyde, acrolein, methanol, and acetaldehyde account for essentially all of the HAP mass 

emissions.

16 USEPA considers CO to be a surrogate for all of the organic HAPs.

17 New RICE if construction began on or after 12/19/02. Reconstructed RICE if reconstruction 

began on or after 12/19/02.

18 Existing RICE if construction or reconstruction began before 12/19/02.
Final Staff Report for Proposed Amended Rule 1110.2

34 May 2005

Emission Limits Existing, new and reconstructed 

SI four-stroke, rich-burn, (4SRB) 

stationary RICE:

 Reduce formaldehyde by 76% 

or more. If construction or 

reconstruction began between 

12/19/02 and 6/15/04, may 

reduce by 75% or more until 

6/15/07; or

• Limit concentration of 

formaldehyde to 0.35 ppmvd

or less @15% oxygen

New and reconstructed lean-burn 

and CI stationary engines

2SLB

 Reduce CO by 58% or more;

or

• Limit formaldehyde to 12

ppmvd or less @15% 

oxygen. If construction or 

reconstruction began 

between 12/19/02 and 

6/15/04 may reduce to 

17ppmvd or less until 

6/15/07.

4SLB

 Reduce CO by 93% or more 

; or

• Limit formaldehyde to 14

ppmvd or less @15% 

oxygen.

CI Engine

 Reduce CO by 70% or 

more; or

 Limit formaldehyde to 0.58 

ppmvd or less @15% 

oxygen.

Stationary engines with an 

Approved Emission Control Plan 

to electrify, but later chose not: 

11 ppm NOx, 30 ppm VOC and 

70 ppm CO at 15% oxygen dry 

basis.

Engines used in the following 

applications:

 Electric power generation

 Fired by landfill gas, 

digester gas, oil field gas or 

liquefied petroleum gas 

(LPG)

 To drive water supply or 

conveyance pump except 

for aeration facilities

 Internal engine-compressor 

applications operating 

4000 hours per calendar 

year

Less than 500 bhp: 45* ppm 

NOx, 250* ppm VOC and 

2000 ppm CO at 15% oxygen 

dry basis

Over 500 bhp:

36* ppm NOx, 250* ppm 

VOC and 2000 ppm CO at 

15% oxygen dry basis

*The NOx and VOC limits 

for engines with a thermal 

efficiency 25% may correct 

limits upward in proportion to 

their thermal efficiency.

All other engines:

36 ppm NOx, 250 ppm VOC and 

2000 ppm CO at 15% oxygen dry 

basis

Operating Limitations Existing, new and reconstructed 

4SRB stationary RICE:

If complying with formaldehyde 

None
Final Staff Report for Proposed Amended Rule 1110.2

35 May 2005

reduction requirements using 

oxidation catalyst (OC):

 Limit OC pressure drop to 

<2 in. w.c increase from 

initial test and maintain OC

inlet temperature inlet to 

750F.

If complying with formaldehyde

reduction requirements and not 

using an OC:

 Operation limits approved 

by EPA Administrator.

New and reconstructed lean-burn 

and CI stationary RICE:

If complying with CO reduction 

requirements or formaldehyde

reduction requirements using an 

OC:

 Limit OC pressure drop to 

<2 in. w.c increase from 

initial test and maintain OC 

inlet temperature inlet to 

450F and 1350F.

If complying with CO reduction 

requirements or formaldehyde

reduction requirements without 

OC:

 Operation limits approved 

by EPA

Testing and 

Monitoring

An initial source test of all subject 

RICE units

Stationary 2SLB, 4SLB and CI 

engines complying with CO 

limits:

 Semi-annual testing of CO 

(and O2) % reduction across 

catalyst.

 If using OC and continuous 

parameter monitoring 

system (CPMS), measure 

the pressure drop and inlet 

All stationary engines:

 Non-resettable totalizing 

time meter.

 Conduct a NOx, VOC and 

CO source test once every 

3 years

Engines 1000 bhp and operating 

two million bhp-hr per calendar 

year:

 CEMS for continuous 

NOx monitoring. 

 An alternative monitoring 
Final Staff Report for Proposed Amended Rule 1110.2

36 May 2005

temperature of catalytic 

oxidizer and maintain 4-

hour rolling averages within 

OC inlet temperature 

operating limits established 

during performance test.

 If not using OC, use CPMS 

to monitor and record 

operating parameters 

approved by EPA and 

maintain 4-hour rolling 

averages of operating 

parameters within limits 

established during 

performance test.

 If using CEMS, measure CO 

(and O2 or CO2) 

continuously at inlet and 

outlet of OC and demonstrate 

CO reduction by 4-hour 

averaging period. Conduct 

annual relative accuracy test 

audit (RATA) of CEMS.

4SRB engines complying with 

formaldehyde limits:

 Measure formaldehyde at 

15% O2, oxygen and 

moisture at inlet and outlet of 

control device.

 If using NSCR, use CPMS to 

measure the pressure drop 

and inlet temperature of

catalyst and maintain 4-hour 

rolling averages within 

operating limits of catalyst 

inlet temperature

 If not using NSCR, use 

CPMS to monitor operating 

parameters approved by EPA 

and maintain 4-hour rolling 

averages of parameters 

within operating limits 

established during 

performance test.

 If bhp 5,000, conduct 

device may be installed 

upon approval by the 

Executive Officer.
Final Staff Report for Proposed Amended Rule 1110.2

37 May 2005

semiannual tests to 

demonstrate compliance with 

formaldehyde limits.

All RICE complying with 

formaldehyde limits:

 Semiannual testing of 

formaldehyde.

 If using OC or NSCR, record 

pressure drop monthly and 

use CPMS to measure 

catalyst inlet temperature 

maintain 4-hour rolling 

averages within operating 

limits

 If not using OC or NSCR, 

use CPMS to monitor 

operating parameters 

approved by EPA and 

approved parameters from 

initial performance test and 

maintain 4-hour rolling 

averages of operating limits 

established during 

performance test .

Recordkeeping and 

Reporting

Keep comprehensive records 

supporting compliance with all 

applicable provisions of the RICE 

NESHAP. Records must be in a 

form suitable and readily 

available for expeditious review 

and be kept for 5 years.

Keep all test reports and logs 

required by rule for 5 years, 

including:

Monthly stationary engine log of:

 Total hours of operation

 Type of fuel used

 Fuel consumption

 Cumulative hours of 

operation since last source 

test

Monthly portable engine log of:

 Total hours of operation

 Type of fuel used

 Fuel consumption

RECLAIM process units may 

keep a quarterly log.
Final Staff Report for Proposed Amended Rule 1110.2

38 May 2005

The proposed amendments to Rule 1110.2 will not change the existing limits for NOx, VOC and 

CO. Proposed amended Rule 1110.2 does not regulate HAP emissions. The only common 

targeted pollutant with the RICE NESHAP is CO. Therefore, the existing as well as the 

proposed amendments to Rule 1110.2 are not in conflict with federal regulations.

AQMD Rules Applying to Gaseous and Liquid-Fueled Engines

AQMD Rule 401 – Visible Emissions, which was last amended on November 9, 2001, prohibits 

the discharge of emissions into the atmosphere from any single source for period or periods 

aggregating more than three minutes in any one hour which will cause: a dark or darker shade as 

that of a number 1 on the Ringelmann chart, as published by the United States Bureau of Mines, 

or of an opacity equal or greater than number 1 on the Ringelmann chart.

AQMD Rule 431.1 – Sulfur Content of Gaseous Fuels, which was last amended on June 12, 

1998, prohibits the sale and use natural gas with a sulfur content exceeding 16 ppm. Rule 431.1 

also prohibits the sale and use of the following gases with a sulfur content exceeding: 150 ppmv 

in landfill gas; 40 ppmv in refinery gas, sewage digester gas and other gases.

AQMD Rule 431.2 – Sulfur Content of Liquid Fuels, which was last amended on September 15, 

2000, prohibits the purchase by stationary source end users of any diesel fuel with a sulfur 

content exceeding 15 ppm on and after June 1, 2004.

AQMD Rule 1303 - New Source Review Requirements, which was last amended on December 

6, 2002, requires Best Available Control Technology, modeling and emission offsets for any new 

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

ozone depleting compound or ammonia.

AQMD Rule 1401 - New Source Review of Toxic Air Contaminants, which was last amended 

on May 2, 2003, specifies limits for maximum individual cancer risk (MICR), cancer burden, 

and noncancer acute and chronic hazard index (HI) from new, modified and existing permitted 

sources which emit toxic air contaminants (TACs) listed in Table I of Rule 1401. Although 

numerous TACs may be emitted from engines, formaldehyde, acrolein, methanol, and 

acetaldehyde account for essentially all of the mass emissions. PAR 1110.2 target pollutants are 

NOx, VOC and CO.

AQMD Rule 1470 - Requirements for Stationary Diesel-Fueled Internal Combustion and Other 

Compression Ignition Engines, which was adopted on April 2, 2004, addresses primarily toxic 

diesel PM, but also NOx, VOC and CO emissions from new and existing, stationary, emergency 

and non-emergency, diesel engines. The requirements of Rule 1470 do not apply to existing 

agricultural engines installed prior to January 1, 2005. 

AQMD Regulation XX - Regional Clean Air Incentive Market (RECLAIM) superceded many 

Regulation IV and Regulation XI rules for NOX and SOX for the largest facilities with an 

emission trading program that achieved equivalent emission reductions, but in a way to allow 

facilities flexibility in achieving emission reduction requirements for NOx and SOx by methods 

such as add-on controls, equipment modifications, reformulated products, operational changes, 

shutdowns, and the purchase of excess emission reductions. Facilities for which emission fee 
Final Staff Report for Proposed Amended Rule 1110.2

39 May 2005

data for 1990 or subsequent year shows four or more tons per year of NOx or SOx, excluding 

certain exempt sources, are subject to this program. Regulation XX specifically identifies 

requirements for IC engines, in addition to other specific sources, which include monitoring, 

reporting and recordkeeping for NOx and SOx emissions.

PERMITTING RECOMMENDATIONS

AQMD’s current Rule 219 – Equipment not Requiring a Written Permit Pursuant to Regulation 

III, exempts from permits engines at agricultural facilities if the facility’s emissions are less than 

50% of the Title V Thresholds. This means that unless the rule is changed, most agricultural 

facilities will not require AQMD permits for their existing engines, for modifications to their 

engines to comply with Rule 1110.2, or for new engines.

Staff recommends that the agricultural engines that are subject to the requirements of Rule 

1110.2 be permitted by the AQMD, regardless of the size of the agricultural operation. 

Experience in implementing Rule 1110.2 has shown that engines require continuous attention by 

the operator to ensure they operate in compliance with AQMD rules. History has also shown 

that without a strong AQMD enforcement presence, engine operators do not adequately maintain 

or operate the engines and control equipment to comply with AQMD rules on a continuous basis. 

It is expected that agricultural engine operators will perform no differently than other operators. 

The permit is the best mechanism that will allow the AQMD to ensure compliance is achieved. 

Without the permits, compliance staff will have difficulty determining which agricultural 

facilities are even subject to the rule, making compliance difficult to enforce. Requiring permits 

for engine modifications and control equipment will assure that the correct steps are taken to 

achieve compliance with Rule 1110.2. The associated permit fees will also allow the AQMD to 

recover the increased compliance costs for agricultural engines directly from those facilities, 

rather than have other fee programs subsidize these increased costs.

California Health and Safety Code Section 42301.16 requires district permits for agricultural 

equipment at facilities below one half of the Title V emission thresholds, provided the AQMD 

Board, at a public hearing, finds that a permit is necessary to impose or enforce reductions of 

emissions of air pollutants that cause or contribute to exceedances of a state or federal ambient 

air quality standard and the requirement for a source or category of sources to obtain a permit 

would not impose a burden on those sources that is significantly more burdensome than other 

similar sources of air pollution. Staff will recommend the Board make those findings at the 

public hearing to consider the proposed amendments to Rule 1110.2. Rule 1110.2 is necessary to 

reduce NOx, VOC and CO emissions in order to achieve and maintain the state and federal 

ambient air quality standards for ozone and particulate matter. Without a written permit for 

those sources subject to the requirements of Rule 1110.2, the standards necessary to ensure the 

emission reductions are unenforceable. The permit requirement and associated fees are the same 

as those imposed on all other engine operators subject to the requirements of Rule 1110.2. The 

socioeconomic assessment found that the permit fees are reasonable compared to other 

industries, therefore, the permit is no more burdensome to agricultural operators than it is to 

other engine operators subject to Rule 1110.2.

In order to implement the permit requirement, an amendment to Rule 219 – Equipment Not 

Requiring a Written Permit Pursuant to Regulation II will be required. Upon the Board approval 

of the required findings, staff will prepare the appropriate amendment to Rule 219 and bring the 
Final Staff Report for Proposed Amended Rule 1110.2

40 May 2005

rule amendment to a public hearing for Board consideration prior to the implementation date of 

Rule 1110.2 for agricultural operations.

DRAFT FINDINGS

Before adopting, amending or repealing a rule, the AQMD shall make findings of necessity, 

authority, clarity, consistency, non-duplication, and reference, as defined in Health and Safety 

Code Section 40727. The draft findings are as follows:

Necessity - The AQMD Governing Board finds and determines that Proposed Amended Rule 

1110.2 - Emissions From Gaseous- and Liquid-Fueled Internal Combustion Engines is necessary 

in order to comply with the requirements of Senate Bill 700-Agricultural Operations and adopt 

and implement Best Available Retrofit Control Technology for inclusion in the State 

Implementation Plan for agricultural sources.

Authority - The AQMD Governing Board obtains its authority to adopt, amend or repeal rules 

and regulations from Health and Safety Code §§40000, 40001, 40440, and 40720-40728.

Clarity - The AQMD Governing Board finds and determines that Proposed Amended Rule 

1110.2 is written and displayed so that the meaning can be easily understood by persons directly 

affected by it.

Consistency – The AQMD Governing Board finds and determines that Proposed Amended Rule 

1110.2 is in harmony with, and not in conflict with or contradictory to, existing statutes, court 

decisions, or federal or state regulations.

Non-Duplication – The AQMD Governing Board has determined that Proposed Amended Rule 

1110.2 does not impose the same requirements as any existing state or federal regulations.

Reference - In adopting these proposed amendments and proposed rescinding, the AQMD 

Governing Board references the following statutes which AQMD hereby implements, interprets 

or makes specific: Health and Safety Code Sections 40001, 40440, and 40724 (SB 700).

In addition, the following draft finding will be necessary to require all agricultural engines 

subject to Rule 1110.2 to obtain AQMD permits, pursuant to Health and Safety Code Section 

42301.16.

Agricultural Engine Permitting – The AQMD Governing Board finds and determines that: 

1) an AQMD permit is necessary for all agricultural engines subject to Rule 1110.2 to impose 

and enforce reductions of NOx and VOC emissions that cause or contribute to the exceedance of 

ozone and particulate ambient air quality standards; and 2) the requirement to obtain a permit is 

not significantly more burdensome for agricultural engine operators than the permit for other 

similar sources of air pollution. 
Final Staff Report for Proposed Amended Rule 1110.2

41 May 2005

REFERENCES

1. California Environmental Protection Agency - Air Resources Board “Determination of 

Reasonably Available Control Technology and Best Available Retrofit Control 

Technology for Stationary Spark-Ignited Internal Combustion Engines", November 2001.

2. South Coast Air Quality Management District, “Final Staff Report For Proposed 

Amendment of Rule 1110.2 - Emissions from Gaseous and Liquid-Fueled Engines” 

November 1997.

3. California Air Resources Board, “Staff Report: Initial Statement of Reasons for Proposed 

Rulemaking for Proposed Amendments to the Regulation for the Statewide Portable 

Equipment Registration Program”, February 26, 2004.

4. Compilation of Air Pollutant Emission Factors AP-42. Volume I: Stationary Point and 

Area Sources. U. S. Environmental Protection Agency, Research Triangle Park, NC.

5. California Air Resources Board, "Staff Report: Adoption of the Proposed Airborne Toxic 

Control Measure for Diesel Particulate Matter from Portable Engines Greater Than 50 

Horsepower", February 26, 2004

6. South Coast Air Quality Management District, “Final Staff Report For Proposed Rule 

1110.2 - Emissions from Gaseous and Liquid-Fueled Engines” July 1990
APPENDIX A

________________________________________________________________

Cost-Effectiveness Calculations
Final Staff Report for Proposed Amended Rule 1110.2

Appendix A A-1 May 2005

Cost-Effectiveness Calculations for Rule 1110.2 Application to Agricultural Engines (2005)

HHV Effic.: 30% (SI), 36% (diesel), Hrs/yr operation: 2000, Load Factor: 65%, Engine hp: 175, No. Engines: 2, 4% Real Interest Rate

PPMVD@15%O2

Case Baseline Controlled % Reduction 10-Yr Tons Reduced

Control Technology NOx CO VOC NOx CO VOC NOx CO VOC NOx CO VOC NH3

Sta Dsl Tier 0 SI Engine + NSCR 1109 394 255 11 70 30 98.8 78.7 85.9 69.3 11.9 4.8 0.00

Electric 1109 394 255 0 0 0 100.0 100.0 100.0 70.2 15.2 5.6 0.00

Tier 1 + SCR + CatOx 1109 394 255 11 70 30 99.0 82.2 88.2 69.5 12.5 5.0 -0.27

Sta Dsl Tier 1 SI Engine + NSCR 546 394 228 11 70 30 97.6 78.7 84.2 33.7 11.9 4.2 0.00

Electric 546 394 228 0 0 0 100.0 100.0 100.0 34.6 15.2 5.0 0.00

SCR 546 394 228 54 2000 300 90.1 0.0 0.0 31.2 0.0 0.0 -0.27

Sta Dsl Tier 2 SI Engine + NSCR 339 394 141 11 70 30 96.1 78.7 74.5 20.6 11.9 2.3 0.00

Electric 339 394 141 0 0 0 100.0 100.0 100.0 21.4 15.2 3.1 0.00

SCR 339 394 141 54 2000 300 84.1 0.0 0.0 18.0 0.0 0.0 -0.27

Sta Dsl Tier 3 SI Engine + NSCR 225 394 36 11 70 30 94.1 78.7 0.7 13.4 11.9 0.0 0.00

Electric 225 394 36 0 0 0 100.0 100.0 100.0 14.2 15.2 0.8 0.00

SCR 225 394 36 54 2000 300 76.0 0.0 0.0 10.8 0.0 0.0 -0.27

Sta SI Tier 0 NSCR 590 1629 23 54 2000 300 90.8 0.0 0.0 38.6 0.0 0.0 0.00

Electric 590 1629 23 0 0 0 100.0 100.0 100.0 42.5 71.5 0.6 0.00

New Engine + NSCR 590 1629 23 11 70 30 98.1 95.7 -32.1 41.7 68.4 -0.2 0.00

Sta SI Tier 1 NSCR 200 1629 7 54 2000 300 73.0 0.0 0.0 10.5 0.0 0.0 0.00

Electric 200 1629 7 0 0 0 100.0 100.0 100.0 14.4 71.5 0.2 0.00
Final Staff Report for Proposed Amended Rule 1110.2

Appendix A A-2 May 2005

AAP $K/Ton

Case Technol, $K

Testing, 

$K

P.V. 10-

Yr $K/Ton Incentive NOx + VOC

Control Technology Inst'd Ann. Ann. Cost, $K NOx + VOC $K w/ AAP

FAC 

HP No. Eng's Eng. HP hrs/yr

Sta Dsl Tier 0 SI Engine + NSCR 84.9 7.3 2.0 163.8 2.2 78.4 1.2 350 2 175 2000

Electric 136.9 -8.3 0.0 67.1 0.9 130.4 -0.8 350 2 175 2000

Tier 1 + SCR + CatOx 120.9 46.7 2.0 532.7 7.2 114.4 5.6 350 2 175 2000

Sta Dsl Tier 1 SI Engine + NSCR 84.9 7.3 2.0 163.8 4.3 78.4 2.2 350 2 175 2000

Electric 136.9 -8.3 0.0 67.1 1.7 130.4 -1.6 350 2 175 2000

SCR 73.6 45.3 2.0 473.6 15.2 67.1 13.0 350 2 175 2000

Sta Dsl Tier 2 SI Engine + NSCR 84.9 7.3 2.0 163.8 7.1 78.4 3.7 350 2 175 2000

Electric 136.9 -8.3 0.0 67.1 2.7 130.4 -2.6 350 2 175 2000

SCR 73.6 45.3 2.0 473.6 26.3 67.1 22.5 350 2 175 2000

Sta Dsl Tier 3 SI Engine + NSCR 84.9 7.3 2.0 163.8 12.2 78.4 6.4 350 2 175 2000

Electric 136.9 -8.3 0.0 67.1 4.5 130.4 -4.2 350 2 175 2000

SCR 73.6 45.3 2.0 473.6 43.8 67.1 37.6 350 2 175 2000

Sta SI Tier 0 NSCR 51.3 15.0 2.0 194.8 5.1 31.8 4.2 350 2 175 2000

Electric 147.7 9.6 0.0 228.4 5.3 128.2 2.3 350 2 175 2000

New Engine + NSCR 84.9 15.0 2.0 228.4 5.5 65.4 3.9 350 2 175 2000

Sta SI Tier 1 NSCR 51.3 15.0 2.0 194.8 18.6 31.8 15.5 350 2 175 2000

Electric 147.7 9.6 0.0 228.4 15.7 128.2 6.9 350 2 175 2000
Final Staff Report for Proposed Amended Rule 1110.2

Appendix A A-3 May 2005

Incremental Cost-Effectiveness Calculations

PPMVD@15%O2 Incr. 10-Yr Tons Technol, $K

Testing, 

$K

Incr. 10-

Yr Incr. $K/ton

Case Technology Pair NOx CO VOC NOx CO VOC Inst'd Ann. Ann. Cost, $K NOx + VOC

Sta Ag Dsl Tier 0, 1 or 2 175-hp Spark + NSCR 54 2000 300 5.4 -31.0 -2.9 44.3 12.0 1.0 120.9 48.2

Tier 3 Engine 225 394 36 24.7 0.0 1.0

Sta Ag SI 175-hp NSCR 54 2000 300 2.0 0.0 0.0 24.2 12.0 1.0 93.5 46.2

Low-Emiss Comb. + 

CatOx 118 2000 300 26.1 0.7 1.0

NSCR 54 2000 300 2.0 0.0 0.0 24.2 12.0 1.0 81.8 40.4

PSC + CatOx 118 2000 300 25.1 2.2 1.0

NSCR 54 2000 300 9.0 -31.0 -1.7 24.2 12.0 1.0 104.0 14.3

Tier 2 Engine 339 394 141 21.5 0.0 1.0
Final Staff Report for Proposed Amended Rule 1110.2

Appendix A A-4 May 2005

Notes:

Average engine size (175 hp) and average No. of engines at facility (2) are based on AQMD survey of agriculural facilities.

Engine operation of 2000 hrs/yr at 65% load factor is based on "The Carl Moyer Memorial Air Quality Standards Attainment Program 

Guidelines", Chapter 6, Stationary Agricultural Irrigation Pump Engines.

Baseline emissions are the uncontrolled values (e.g., AP-42) or the required value (USEPA Tier), whichever is lower.

 Ratio of NOx:VOC g/bhp-hr for Tier 2 diesel engines assumed same as Tier 1 diesel engines.

 Ratio of NOx:VOC g/bhp-hr for Tier 3 diesel engines assumed same as Tier 4 diesel engines.

 Ratio of NOx:VOC g/bhp-hr for certified SI engines assumed same as for uncontrolled SI engines.

Controlled emissions are based on BACT for engine replacements or the rule requirements (including efficiency ratio multiplier) for add-on 

controls.

Cost of replacement engine: diesel: Tier 1 or 2 $123/hp, Tier 3 $131/hp, Tier 4 $140/hp; SI:Tier 0 $92/hp, Tier 2 $92/hp + $723

 $123/hp for Tier 1 or 2 diesel is from SJVUAPCD Proposed Amendments to Rule 4702, Draft Staff Report, January 3, 2005, Appendix C.

 $131/hp for Tier 3 diesel is based on information from manufacturers (15% increase in cost of engine [which is approx. $50/hp])

 $140/hp for Tier 4 diesel assumes another 15% increase in cost of engine.

 $92/hp for SI engine is factored from cost of diesel (75%). Added cost for Tier 2 SI engine of $723 is from USEPA (Final Regulatory 

Support Document, Control of Emissions from Unregulated Nonroad Engines, EPA420-R-02-022, September 2002) escalated at 2.5% 

inflation rate.

Cost of engine replacement does not take credit for efficiency improvement and lower maintenance cost.

Cost of NSCR system: $22.06k per eng.+$28.7(hp-100) installed, $6.6k per eng.+$7.2(hp-100) annual O&M (from CARB RACT/BARCT 

determination for SI engines, escalated at 2.5% inflation rate).

Cost of SCR system: $49.6k per engine+$96(hp-100) installed, $22k per engine+$93(hp-100) annual O&M (from CARB RACT/BARCT 

determination for SI engines, escalated at 2.5% inflation rate).

10-Yr Cost for SCR includes cost to control 10-Yr tons PM created by unreacted ammonia (NH3) (10 ppm in exhaust gas) valued at 

$4,500/ton (BACT cost effectiveness criterion)

Cost of oxidation catalyst: $12/hp (from CARB RACT/BARCT determination for SI engines, escalated at 2.5% inflation rate), 3-yr catalyst 

life assumed.

Cost of electrification: $391/hp based on AQMD Contract No. 03143, replacement of 34 diesel pumps with electric pumps.

 Cost to connect diesel engine to grid assumed zero based on funding program available from SCE to assist electrification of diesel 

engines.

 For SI engines, cost for connection to grid is assumed to be $10.8k (from CARB RACT/BARCT, escalated at 2.5% inflation rate).

Fuel costs used to calculate annual energy cost of fuel switch or electrification ($/MMBtu): Diesel 11.5, Propane 8, Natural Gas 7.6, 

Gasoline 15 --based on information from U.S. Energy Information Agency and So. Cal Gas core rate for water pumping effective 2/1/05.

Electrification of SI engine assumes the baseline energy source is natural gas (based on AQMD survey of agricultural facilities).

Electricity rates for conversion from diesel assumed to be SCE proposed TOU-PA-ICE rate schedule (time-weighted average rate 

$.0592/kW-hr plus monthly charges of $50.51 meter charge, $2.89/kW demand charge and $1.09/kW summer on-peak demand charge).

Electricity rates for conversion from gas assumed to be SCE TOU-PA-B rate schedule (time-weighted average rate $.0656/kW-hr plus 
Final Staff Report for Proposed Amended Rule 1110.2

Appendix A A-5 May 2005

monthly charges of $50.51 meter charge, $4.18/kW demand charge and $8.25/kW summer on-peak demand charge).

Cost of source testing: $3k per engine, every 3 years

For incremental cost effectiveness of NSCR vs. Low-Emission Combustion Modifications (LEC) or Pre-Stratified Charge (PSC):

 LEC or PSC is assumed 80% effective on NOx (CARB RACT/BARCT Determination), and it is assumed that oxidation catalyst can meet 

the amended rule limits on CO and VOC.

 Cost of LEC for 175 hp engine is $24k installed and no annual cost. Cost of PSC for 175 hp engine is $23k and $1.5k/yr (CARB

RACT/BARCT Determination)

For incremental cost effectiveness calculations, Ignition Timing Retard is assumed to be 15% effective on NOx and cost $4.7k/yr (CARB 

RACT/BARCT)

Agricultural Assistance Program (AAP) incentive funds are available to offset cost of modifying or replacing diesel engines, up to $13,600 

per ton of NOx+VOC+PMx10 reduced.

 For calculation of AAP cost effectiveness, used 0.117 factor for annual value of incentive (10-yr life, 3% discount rate).

For Socio-Econ Calculations:

 Assumed approx half SI engines and 80% of the diesel engines would be electrified and sites that have most hp and most hrs/yr 

operation would be most likely to be electrified.

 For each engine, calculated costs for that engine size and hrs/yr operation and for the number of engines at the site where it is located - 

-i.e., calculated costs for a facility having N engines all rated at same hp and all engines operating same hrs/yr, then divided by N.

 Calculated Agricultural Assistance Program (AAP) cost effectiveness using AAP incentive x 0.117 (10-yr life, 3% discount rate) divided 

by tpy NOx, VOC, PM x 10.

 PM emission from diesel-fueled engine assumed to be .0022 lb/hp-hr for Tier 0 (AP-42, Table 3.3-1) and required values for Tier 1 and 

above (dependent on hp of engine).

 PM emission from SI engine assumed to be .01942 lb/MMBtu (AP-42, Table 3.2-3 [natural gas])

Installed cost is reduced by AAP incentive. AAP incentive = installed cost - cost to rebuild engine; up to a cost effectiveness of $13,600 

per ton.

 Cost to rebuild diesel engine = $1.5k + $.01k x hp, based on default rebuild costs used in SJVAPCD CMP Ag pump component)

 Cost to rebuild SI engine = 3 x cost to rebuild diesel engine, based on information from engine rebuild shops.
APPENDIX B

________________________________________________________________

Incentive Funding Available for Agricultural Engine Emission 

Reductions
Final Staff Report for Proposed Amended Rule 1110.2

Appendix B B-1 May 2005

Summary of Incentive Funding Available for 

Agricultural Engine Emission Reductions

There are two important new incentive programs for agricultural engine emission reduction 

projects, one from the State of California, and the other from Southern California Edison 

Company. The new state Agricultural Assistance Program (AAP) is unprecedented in that it 

will provide funding to agricultural facilities for emissions reductions required by an AQMD 

regulation. No other facilities enjoy this kind of financial assistance. 

There are a variety of other AQMD programs (see AQMD’s website at 

http://www.aqmd.gov/tao/Implementation/index.htm) that provide incentive funding for 

emission reduction projects. However, they cannot fund emission reductions required by AQMD 

rules. Therefore, the following two programs will be the best source of funding for agricultural 

engines. 

Carl Moyer and Agricultural Assistance Programs

Since 1998, the Carl Moyer Memorial (CMP) Air Quality Standards Attainment Program 

(“Carl Moyer Program”) has provided grants to encourage the owners of heavy-duty diesel 

engines to go beyond regulatory requirements by retrofitting, repowering, or replacing their 

engines with newer and cleaner ones. On January 1, 2005, new legislation (AB 923, Firebaugh) 

takes effect which broadens the definition of Carl Moyer Program (CMP)-eligible projects to 

include additional agricultural sources. 

CMP grants are awarded based on funding protocols developed in consultation with local air 

districts and interested stakeholders, and adopted by the CARB in a public meeting. The 

definition of “agricultural sources” in AB 923 includes sources such as confined animal facilities 

and fugitive dust, for which there are currently no funding protocols. Projects for which funding 

protocols exist, such as projects involving agricultural irrigation pump engines, will continue to 

be eligible for funding. 

The legislation requires the CARB to establish or update grant criteria and guidelines for covered 

projects, as revised by the bill, by January 1, 2006. CARB has issued interim guidelines19; 

however, they will eventually be superceded by CARB-adopted guidelines. After October 2005, 

interested persons should consult http://www.arb.ca.gov/msprog/moyer/moyer.htm or CARB 

staff to determine if final Board-adopted guidelines are available. 

Table B-1 summarizes the significant differences between the CMP and the new Agricultural 

Assistance Program authorized by AB 923 and funded by the $2 motor vehicle registration fee.

 

19 Carl Moyer Program Advisory: 05-002 November 29, 2004
Final Staff Report for Proposed Amended Rule 1110.2

Appendix B B-2 May 2005

Table B-1: Agricultural Source Eligibility for

Carl Moyer Program and $2 Motor Vehicle Registration Fee Incentive Funds

Carl Moyer Program Agricultural Assistance Program

(funded with $2 MV Fees)

 

Program Criteria*

 Reductions must be surplus

 $13,600 cost-effectiveness limit

 Previously unregulated sources

 Within 3 years after rule adoption or 

before compliance date (whichever is 

later)

 No surplus requirement

 $13,600 cost-effectiveness of total 

reductions limit

*Summary of eligibility criteria. Please consult the CMP Guidelines20 and the Program Advisory 05-002 for 

complete eligibility information. . 

AB 923 will permit the funding of incentive programs to reduce emissions of nitrogen oxides 

(NOx) , particulate matter (PM) and reactive organic gases (ROG). The bill also authorizes 

funding for additional agricultural sources. Two funding sources – the CMP and an additional 

two dollar surcharge on motor vehicle registration fees are affected. For the purposes of AB 923, 

agricultural sources are defined in Health and Safety Code Section 39011.5. This section defines 

an agricultural source as a source of air pollution used in the production of crops, or the raising 

of fowl or animals, that meets any of the following criteria:

 Is a confined animal facility;

 Is an internal combustion engine used in the production of crops or the raising of fowl or 

animals, except an engine that is used to propel implements of husbandry;

 Is a Title V source; or

 Is a source that is otherwise subject to regulation by a district pursuant to federal law (for 

example, fugitive dust sources subject to federal control requirements).

For purposes of the motor vehicle registration fee, self-propelled agricultural equipment, such as 

tractors or harvesters, are specifically excluded from the definition of “agricultural sources” 

under this section of the Health and Safety Code. However, self-propelled equipment is eligible 

for funding under the “traditional” CMP because it is a mobile source.

The CMP and the motor vehicle registration fee program are governed by related but different 

statutory requirements:

 For CMP projects, emission reductions must be real, surplus, quantifiable, and enforceable. 

“Surplus” means that the reductions must surpass those reductions required by existing 

regulatory requirements. Projects must also meet a cost-effectiveness threshold of $13,600 

per ton of emissions reduced. 

 

20 See http://www.aqmd.gov/tao/Implementation/carl_moyer_program_2001.html
Final Staff Report for Proposed Amended Rule 1110.2

Appendix B B-3 May 2005

 The $2 motor vehicle fee can be used to fund agricultural projects in two ways. The $2 

motor vehicle fee can be used to fund agricultural projects meeting the CMP guidelines. In 

addition, the $2 motor vehicle fee may be used to directly fund agricultural projects through a 

new program called the “Agricultural Assistance Program” (AAP) if specified conditions are 

met. AAP projects must apply to previously unregulated sources. These projects do not 

need to provide surplus emission reductions. 

At this time, there is already a CMP funding protocol for projects that reduce emissions from 

agricultural pump engines. As discussed in Program Advisory 04-13, projects that reduce 

emissions from both stationary and portable agricultural irrigation pump engines are eligible for 

funding. In addition, Program Advisory 05-001 modifies the requirements for project life, 

allowing all agricultural irrigation pump engines (including portable engines) to qualify for 

funding beyond the December 31, 2004 date specified in Program Advisory 04-13.:

As discussed above, AB 923 broadens the definition of CMP-eligible projects to include 

additional agricultural sources. There are currently no funding protocols for projects that reduce 

emissions from agricultural sources that are not engines. CARB staff is evaluating the eligibility 

of projects to reduce emissions from the other types of agricultural sources.

Existing law authorizes air districts to assess motor vehicle fees to fund implementation of the 

California Clean Air Act. AB 923 modifies the law to allow district boards to adopt an 

additional surcharge of up to $2 to implement any or all of four specified programs: the CMP; 

Low-Emission School Bus Program; a car scrap program; or the new purchase, retrofit, repower, 

or add-on equipment for previously unregulated agricultural sources. 

Emission reductions from agricultural projects that meet the CMP guidelines may be funded with 

the $2 surcharge on motor vehicles. The $2 surcharge on motor vehicles may also be used under 

a new program called the “Agricultural Assistance Program” (AAP) to directly fund the control 

of agricultural sources of air pollution, as defined in Section 39011.5.” 

Based on the statutory provisions of AB 923, AAP projects must meet all of the following 

requirements:

– Projects must involve the new purchase, retrofit, repower or add-on of equipment,

– Projects must reduce emissions from previously unregulated sources; that is sources that are 

unregulated as of January 1, 2005, the effective date of the legislation, but are subject to 

regulation at the time of the grant (this includes agricultural engines),

– Projects must be funded within 3 years of rule adoption or before the compliance date of the 

rule, whichever is later, and

– The ARB must determine that the applicable rule complies with Sections 40913, 40914, and 

41503 of the Health and Safety Code pertaining to attainment plan measures.

Sections 40913, 40914, and 41503.1 of the Health and Safety Code relate to California Clean Air 

Act attainment plans and the rate of emission reductions required in those plans. District plans 

must be designed to achieve and maintain the state ambient air quality standards by the earliest 

practicable date through the use of all feasible measures. CARB routinely reviews district rules 

for compliance with these requirements and will treat agriculture-related rules the same way.
Final Staff Report for Proposed Amended Rule 1110.2

Appendix B B-4 May 2005

Agricultural irrigation pump engines subject to district rules that limit NOx, ROG or PM 

emissions from agricultural irrigation pump engines can be funded if those rules take effect after 

January 1, 2005, as will the proposed amendments to Rule 1110.2. The project must also meet 

the AAP criteria listed above, and should meet the cost-effectiveness of total reduction (CETR) 

limit of $13,600 per ton as described below.

Because AAP projects are not required to achieve surplus emission reductions, the costeffectiveness calculations used in the CMP (which are based solely on surplus reductions) are not 

appropriate for evaluating these types of projects. 

However, in order to provide a means for districts to evaluate AAP projects, ARB staff has 

developed a new metric for the AAP, the “cost-effectiveness of total reductions” (CETR), where 

CETR is the annualized cost divided by the emission reductions as if no regulatory requirement 

existed:

Annualized Cost ($/year)

Emission Reductions if no Regulatory Requirement Existed (tons/yr)

The emission reductions should be calculated using CMP methodologies and protocols, but 

assuming no regulatory requirement exists. For example, for agricultural irrigation pump 

engines, the CETR calculation would generally assume a project life of 7 years, even if a local 

rule for agricultural irrigation pump engines takes effect in three years. 

In order to ensure that the technologies and costs of projects funded by the AAP are generally 

comparable to those funded by the CMP, local districts should not directly fund agricultural 

projects that exceed a CETR of $13,600 per ton of total emissions reduced, but matching funds 

from the engine user or other source are not counted toward the CETR limit. 

Southern California Edison (SCE) Incentive Funding and Reduced Electric Rates

SCE already has ten different rate schedules for agricultural customers that offer better electric 

rates to agricultural facilities than to other commercial and industrial customers. Nevertheless, 

on November 9, 2004, SCE filed an application with the California Public Utilities Commission 

for expedited approval of additional incentives for conversion of agricultural engines to electrical 

service. SCE’s proposal consists of two incentives to encourage customers to convert to 

electrical use: discounted rates over a 10-year period; and enhanced line extension allowances to 

help reduce the up-front costs of the conversion.

The proposed new rate schedule, Schedule TOU-PA-ICE Time-of-Use Agricultural and 

Pumping internal Combustion Engine Conversion Program, represents approximately a 20% 

discount relative to the current Schedule TOU-PA-B. Both demand charges ($/kW) and energy 

charges ($/kW-hr) are reduced. During the Off-Peak time period, electric costs will be as low as 

4.532 cents per kW-hr. This is equivalent to buying diesel fuel at $0.63 per gallon, which is 

much less than the current cost of diesel fuel, therefore the operating costs of the electric motor 

will be much less than for a diesel engine.

In order to help pay more of the up-front costs to bring electrical service to an agricultural site, 

SCE also proposes additional Line Extension Adder funding on top off the funding already in 
Final Staff Report for Proposed Amended Rule 1110.2

Appendix B B-5 May 2005

effect. SCE estimates that a typical 150 hp diesel engine would qualify for an additional $30,000 

of funding in addition to the normal funding.

Agricultural facilities can get these SCE incentives in addition to the state AAP incentives when 

the convert agricultural engines to electric service.
APPENDIX C

________________________________________________________________

SB 700 Excerpts
Final Staff Report for Proposed Amended Rule 1110.2

Appendix C C-1 May 2005

BILL NUMBER: SB 700 CHAPTERED

BILL TEXT

CHAPTER 479

FILED WITH SECRETARY OF STATE SEPTEMBER 22, 2003

APPROVED BY GOVERNOR SEPTEMBER 22, 2003

PASSED THE SENATE SEPTEMBER 11, 2003

PASSED THE ASSEMBLY SEPTEMBER 10, 2003

AMENDED IN ASSEMBLY SEPTEMBER 9, 2003

AMENDED IN ASSEMBLY SEPTEMBER 4, 2003

AMENDED IN ASSEMBLY AUGUST 21, 2003

AMENDED IN ASSEMBLY JULY 14, 2003

AMENDED IN ASSEMBLY JULY 2, 2003

AMENDED IN ASSEMBLY JUNE 26, 2003

AMENDED IN SENATE MAY 13, 2003

AMENDED IN SENATE MAY 7, 2003

AMENDED IN SENATE APRIL 24, 2003

INTRODUCED BY Senators Florez and Sher

 FEBRUARY 21, 2003

 An act to amend Section 42310 of, and to add Sections 39011.5,

39023.3, 40724, 40724.5, 40724.6, 40724.7, 40731, 42301.16, 42301.17,

42301.18, and 44559.9 to, the Health and Safety Code, relating to

air quality.

LEGISLATIVE COUNSEL'S DIGEST

 SB 700, Florez. Air quality: emissions: stationary sources:

agricultural operations.

 (1) Existing law authorizes the board of every air quality

management district and air pollution control district to establish a

permit system that requires any person that uses certain types of

equipment that may cause the emission of air contaminants to obtain a

permit. Existing law exempts vehicles and certain types of

equipment from those permit requirements.

 This bill would eliminate that exemption for any equipment used in

agricultural operations in the growing of crops or the raising of

fowl or animals. To the extent that the bill would increase the

number of permits that a district board, electing to establish a

permit system prior to January 1, 2004, would be required to issue,

the bill would impose a state-mandated local program.

 (2) Existing law defines various terms governing the construction

of air pollution control laws in the state, and authorizes the state
Final Staff Report for Proposed Amended Rule 1110.2

Appendix C C-2 May 2005

board to revise those definitions to conform with federal law.

 This bill would define the terms "agricultural source of air

pollution" and "fugitive emissions," and would prohibit,

notwithstanding the existing authority, the state board from revising

those definitions.

 (3) The existing federal Clean Air Act requires districts to adopt

local programs for issuing operating permits to major stationary

sources of air pollutants. The existing act defines a stationary

source as any building, structure, facility, or installation that

emits or may emit any air pollutant.

 This bill would require each district that is designated a serious

federal nonattainment area for an applicable ambient air quality

standard for particulate matter as of January 1, 2004, to adopt,

implement, and submit for inclusion in the state implementation plan,

a rule or regulation requiring best available control measures

(BACM) and best available retrofit control technology (BARCT) for

agricultural practices at agricultural sources of air pollution to

reduce air pollutants from those sources for which that technology is

applicable for agricultural practices by the earliest feasible date,

but not later than January 1, 2006, and would require each district

subject to those requirements to comply with a schedule for public

hearing, adoption, and implementation of the final rule.

 The bill would require each district that is designated a moderate

federal nonattainment area or an applicable ambient air quality

standard for particulate matter as of January 1, 2004, to adopt and

implement control measures necessary to reduce emissions from

agricultural practices by the earliest feasible date, but no later

than January 1, 2007, unless the district determines that those

sources do not significantly cause or contribute to a violation of

state or federal standards.

 The bill would require, by January 1, 2005, the state board to

review all available scientific information and develop a definition

of a "large confined animal facility."

 The bill would require, by July 1, 2006, each district that is

designated as a federal nonattainment area for ozone as of January 1,

2004, to adopt, implement, and submit for inclusion in the state

implementation plan, a rule or regulation that requires the owner or

operator of a large confined animal facility as that term is defined

by the state board to obtain a permit to reduce, to the extent

feasible, emissions of air contaminants from the facility. The bill

would require the district to perform an assessment of the impacts of

the rule or regulation prior to its adoption. The bill would

authorize a permitholder to appeal any district determination or

decision related to that permit.

 The bill would require a district that is designated as being in

attainment for the federal ambient air quality standard for ozone as
Final Staff Report for Proposed Amended Rule 1110.2

Appendix C C-3 May 2005

of January 1, 2004, to adopt the same rule or regulation required of

nonattainment districts, by July 1, 2006, unless the district board

makes a determination that large confined animal facilities will not

contribute to a violation of any state or federal ambient air quality

standard. The bill would provide the rule or regulation is not

required to be submitted for inclusion into the state implementation

plan.

 The bill would require the California Air Pollution Control

Officers Association, in consultation with the state board and other

interested parties, by January 1, 2005, to develop a clearinghouse of

available control measures and strategies for agricultural sources

of air pollution and emissions of air contaminants from agriculture

operations.

 The additional duties for districts under the bill would impose a

state-mandated local program.

 (4) Existing law establishes the Capital Access Loan Program for

Small Businesses, administered by the California Pollution Control

Financing Authority, which provides loans through participating

financial institutions to entities authorized to conduct business in

the state and whose primary business location is in the state.

 This bill would require the authority to expand the program to

include outreach to financial institutions that service agricultural

interests in the state for the purposes of funding air pollution

control measures.

 (5) Under existing law, any person who violates a rule,

regulation, permit, or order of a district is guilty of a

misdemeanor. Because this bill would increase the number of people

who are subject to that provision, it would expand the scope of a

crime, thereby imposing a state-mandated local program.

 (6) The California Constitution requires the state to reimburse

local agencies and school districts for certain costs mandated by the

state. Statutory provisions establish procedures for making that

reimbursement.

 This bill would provide that no reimbursement is required by this

act for specified reasons.

THE PEOPLE OF THE STATE OF CALIFORNIA DO ENACT AS FOLLOWS:

 SECTION 1. (a) The Legislature finds and declares all of the

following:

 (1) Agricultural operations necessary for growing crops or raising

animals are a significant source of directly emitted particulates,

and precursors of ozone and fine particulate matter. These emissions

have a significant adverse effect on the ability of areas of the
Final Staff Report for Proposed Amended Rule 1110.2

Appendix C C-4 May 2005

state, including, but not limited to, the San Joaquin Valley, to

achieve health-based state and federal ambient air quality standards.

 (2) Since 1999, the agriculture industry has reduced emissions of

oxides of nitrogen (NOx) by more than 2000 tons per year, emissions

of particulate matter of 10 microns in diameter (PM 10) by more than

500 tons per year, and emissions of volatile organic compounds (VOCs)

from agricultural chemicals by more than 20 percent. According to

the state board, however, agricultural sources of air pollution still

contribute twenty-six percent of the smog-forming emissions in the

San Joaquin Valley.

 (3) In the San Joaquin Valley, a large portion of the sources of

particulate emissions are areawide sources whose emissions are

directly related to growth in population and the resulting vehicle

miles traveled. According to the State Air Resources Board, however,

agricultural sources of air pollution account for over fifty percent

of the directly emitted particulate air pollution generated in the

valley during the fall, amounting to over 170 tons per day of

emissions.

 (4) All parties living or operating a business in an area that has

been classified as being a nonattainment area with respect to the

attainment of federal or state ambient air quality standards share

the responsibility of reducing emissions from air pollutants.

 (5) The federal Clean Air Act (42 U.S.C. Sec. 7401 et seq.)

prohibits the state from adopting emission standards or limitations

less stringent than those established under the federal act,

including limitations on emissions from agricultural sources.

 (6) Division 26 (commencing with Section 39000) of the Health and

Safety Code establishes numerous policies and programs to reduce air

pollutants for the protection of public health.

 (7) The purpose of the act adding this section is to establish a

new set of programs at the state and regional levels to reduce air

emissions from agricultural sources in order to protect public health

and the environment.

 (b) It is therefore the intent of the Legislature to require the

State Air Resources Board and air quality management districts and

air pollution control districts in the state to regulate stationary,

mobile, and area sources of agricultural air pollution.

 SEC. 2. Section 39011.5 is added to the Health and Safety Code, to

read:

 39011.5. (a) "Agricultural source of air pollution" or

"agricultural source" means a source of air pollution or a group of

sources used in the production of crops, or the raising of fowl or

animals located on contiguous property under common ownership or

control that meets any of the following criteria:

 (1) Is a confined animal facility, including, but not limited to,
Final Staff Report for Proposed Amended Rule 1110.2

Appendix C C-5 May 2005

any structure, building, installation, barn, corral, coop, feed

storage area, milking parlor, or system for the collection, storage,

treatment, and distribution of liquid and solid manure, if

domesticated animals, including, but not limited to, cattle, calves,

horses, sheep, goats, swine, rabbits, chickens, turkeys, or ducks are

corralled, penned, or otherwise caused to remain in restricted

areas for commercial agricultural purposes and feeding is by means

other than grazing.

 (2) Is an internal combustion engine used in the production of

crops or the raising of fowl or animals, including, but not limited

to, an engine subject to Article 1.5 (commencing with Section 41750)

of Chapter 3 of Part 4 except an engine that is used to propel

implements of husbandry, as that term is defined in Section 36000 of

the Vehicle Code, as that section existed on January 1, 2003.

Notwithstanding subdivision (b) of Section 39601, the state board may

not revise this definition for the purposes of this section.

 (3) Is a Title V source, as that term is defined in Section

39053.5, or is a source that is otherwise subject to regulation by a

district pursuant to this division or the federal Clean Air Act (42

U.S.C. Sec. 7401 et seq.).

 (b) Any district rule or regulation affecting stationary sources

on agricultural operations adopted on or before January 1, 2004, is

applicable to an agriculture source.

 (c) Nothing in this section limits the authority of a district to

regulate a source, including, but not limited to, a stationary source

that is an agricultural source, over which it otherwise has

jurisdiction pursuant to this division, or pursuant to the federal

Clean Air Act (42 U.S.C. Sec. 7401 et seq.) or any rules or

regulations adopted pursuant to that act that were in effect on or

before January 1, 2003, or to exempt an agricultural source from any

requirement otherwise applicable under Sections 40724 or 42301.16,

based upon a finding by the district in a public hearing that the

aggregate emissions from that source do not exceed a de minimus level

of more than one ton of particulate matter, nitrogen oxides or

volatile organic compounds per year.

.

.

.

 SEC. 4. Section 40724 is added to the Health and Safety Code, to

read:

 40724. (a) Each district that is designated as a serious federal

nonattainment area for an applicable ambient air quality standard for

particulate matter as of January 1, 2004, shall adopt, implement,

and submit for inclusion in the state implementation plan, a rule or

regulation requiring best available control measures (BACM) for

sources for which those measures are applicable and best available
Final Staff Report for Proposed Amended Rule 1110.2

Appendix C C-6 May 2005

retrofit control technology (BARCT) to reduce air pollutants from

sources for which that technology is applicable for agricultural

practices, including, but not limited to, tilling, discing,

cultivation, and raising of animals, and for fugitive emissions from

those agricultural practices a manner similar to other source

categories by the earliest feasible date, but not later than January

1, 2006. The rule or regulation shall also include BACM and BARCT to

reduce precursor emissions in a manner commensurate to other source

categories that the district show cause or contribute to a violation

of an ambient air quality standard. Each district that is subject to

this subdivision shall comply with the following schedule with

respect to the rule or regulation imposing BACM and BARCT:

 (1) On or before September 1, 2004, notice and hold at least one

public workshop for the purpose of accepting public testimony on the

proposed rule or regulation.

 (2) On or before July 1, 2005, adopt the final rule or regulation

at a noticed public hearing.

 (3) On or before January 1, 2006, commence implementation of the

rule or regulation.

 (b) Nothing in this section shall delay or otherwise affect any

action taken by a district to reduce emissions of air contaminants

from agricultural sources, or any other requirements imposed on a

district or a source of air pollution pursuant to the federal Clean

Air Act (42 U.S.C. Sec. 7401 et seq.).

 (c) In adopting a rule or regulation pursuant to this section, a

district shall do all of the following:

 (1) Ensure the size and duration of use of an internal combustion

engine subject to BARCT pursuant to this section is commensurate to

the size and duration of use of internal combustion engines subject

to regulation by a district or the state board regulated at other

stationary sources.

 (2) Ensure that BARCT established pursuant to this section for an

internal combustion engine is similar to BARCT for other stationary

source engines subject to regulation by a district or the state

board.

 (3) Ensure that the cost-effectiveness of BARCT for an internal

combustion engine subject to this section is similar to the

cost-effectiveness of BARCT for other internal combustion engines

subject to regulation by a district or the state board.

 (4) Compare the cost-effectiveness of BARCT for an internal

combustion engine subject to this section to the list of available

and proposed control measures prepared pursuant to Section 40922.

 (5) Adopt control measures pursuant to this section in order of

their cost-effectiveness, unless a district determines that a

different order of adoption is necessary due to the enforceability,

public acceptability, or technological feasibility of a given control
Final Staff Report for Proposed Amended Rule 1110.2

Appendix C C-7 May 2005

measure, or to expeditiously attain or maintain a national or state

ambient air quality standard.

 (6) Except as otherwise provided under this section, ensure that

any rule or regulation adopted pursuant to this section complies with

all applicable requirements of this division, including, but not

limited to, any applicable requirements established pursuant to

Sections 40703, 40727, 40728.5, and 40920.6.

 (7) Hold at least one public meeting that is conducted at a time

and location that the district determines is convenient to the public

at which the district reviews the comparison prepared pursuant to

paragraph (4).

 (d) Nothing in this section limits the authority of a district to

regulate a source including, but not limited to, a stationary source

that is an agricultural source over which it otherwise has

jurisdiction pursuant to this division or the federal Clean Air Act

(42 U.S.C. Sec. 7401 et seq.) or any rules or regulations adopted

pursuant to that act. Nothing in this section shall delay or

otherwise affect any action taken by a district to reduce emissions

of air contaminants from agricultural sources, or any other

requirements imposed upon a district or a source of air pollution

pursuant to the federal Clean Air Act. This section may not be

interpreted to delay or otherwise affect the adoption,

implementation, or enforcement of any measure that was adopted, or

included in a rulemaking calendar or air quality implementation plan

that was adopted, by the district prior to January 1, 2004.

.

.

.

SEC. 8. Section 40731 is added to the Health and Safety Code, to

read:

 40731. In order to assist in the development of the BACM, RACM,

and BARCT measures specified in Sections 40724, 40724.5, and 40724.6,

and to reduce or eliminate emissions of regulated air pollutants and

their precursors, the California Air Pollution Control Officers

Association, in consultation with the state board and other

interested parties, shall, not later than January 1, 2005, develop a

clearinghouse of available control measures and strategies for

agricultural sources of air pollution and emissions from agricultural

operations, including, but not limited to, the following sources:

 (a) Operations that create fugitive dust emissions, including, but

not limited to, discing, tilling, material handling and storage, and

travel on unpaved roads.

 (b) Confined animal facilities, including, but not limited to, any

structure, building, installation, barn, corral, coop, feed storage

area, or milking parlor, including, but not limited to, a system for

the collection, storage, treatment, and distribution of liquid or
Final Staff Report for Proposed Amended Rule 1110.2

Appendix C C-8 May 2005

solid manure from domestic animals, including, but not limited to,

cattle, calves, horses, sheep, goats, swine, rabbits, chickens,

turkeys, or ducks, if those animals are corralled, penned, or

otherwise caused to remain in restricted areas for commercial

agricultural purposes, and feeding is by means other than grazing.

 (c) Internal combustion engines used in the production of crops or

the raising of animals or fowl, except an engine that is used to

propel an implement of husbandry, as that term is defined in Section

36000 of the Vehicle Code, as that section existed on January 1,

2003.

 (d) Other equipment, operations, or activities associated with the

growing of crops or the raising of fowl or animals, that emit, or

cause to be emitted, any regulated air pollutant, or any precursor to

any regulated air pollutant.
APPENDIX D

________________________________________________________________

Stationary, Non-Emergency Agricultural Engines Emissions Inventory
Final Staff Report for Proposed Amended Rule 1110.2

Appendix D D-1 May 2005

BASIS:

* 30% thermal efficiency for natural gas engines

* 65% load for all engines

* Uncontrolled diesel engine emission factors per U.S. EPA AP-42 

 Compilation of Air Pollution Emission Factors, Table 3.3-1

 14.0 NOx, 3.03 CO, 1.12 VOC and 1.0 PM, all as g/hp-hr

* Uncontrolled natural gas four-stroke, rich-burn engine emission factors per U.S. EPA AP-42 

 Compilation of Air Pollution Emission Factors, Tables 3.2-2 and 3.2-3

 8.47 NOx, 14.3 CO, 0.113 VOC and 0.0749 PM, all as g/hp-hr

*

Tier 1 (175hp < 300hp) diesel engine emission factors per U.S. EPA non-road diesel emission 

standards

 6.9 NOx, 8.5 CO, 1.0 VOC and 0.4 PM, all as g/hp-hr

* Tier 2 (50hp < 75hp) diesel engine emission factors per U.S. EPA non-road diesel emission standards

 4.9 NOx, 3.7 CO, 0.71 VOC and 0.3 PM, all as g/hp-hr

(for NOx and VOC emission factors, the same ratio as in Tier 1 was used)

STATIONARY IRRIGATION PUMPS

STATIONARY IRRIGATION PUMPS

STATIONARY IRRIGATION 

PUMPS Annual Emissions 

(lbs/year)

SURVEY 

NUMBER HP Hrs/Year Diesel

Natural 

Gas N0x VOC CO PM

24 150 300 1 546 7 902 5

54 150 600 1 1814 144 391 129

299 60 438 1 <Tier 2> 183 27 139 11

334 75 1600 1 2418 193 521 172

334 75 1600 1 2418 193 521 172

334 75 1600 1 2418 193 521 172

349 300 3000 1 18135 1445 3908 1287

351 75 364 1 331 4 547 3

Tons/Year 14.1 1.10 3.73 0.975
Final Staff Report for Proposed Amended Rule 1110.2

Appendix D D-2 May 2005

STATIONARY WELL/WATER PUMPS

STATIONARY WELL/WATER PUMPS

STATIONARY WELL/WATER 

PUMPS Annual Emissions 

(lbs/year)

SURVEY 

NUMBER HP Hrs/Year Diesel Natural Gas N0x VOC CO PM

28 465 3000 1 28109 2240 6057 1995

28 330 3000 1 19949 1589 4299 1416

28 227 3000 1 13722 1093 2957 974

28 145 3000 1 5275 69 8719 47

85 60 1460 1 1062 14 1756 9

85 150 1460 1 2656 34 4390 23

106 100 270 1 327 4 541 3

339 175 3600 1 7640 99 12628 68

471 200 4320 1 10477 136 17318 93

471 200 4320 1 10477 136 17318 93

471 250 4320 1 13097 170 21648 116

Tons/Year 56.4 2.79 48.8 2.42

OTHER AG ENGINES

OTHER AG ENGINES -

UNCONTROLLED 

Annual Emissions (lbs/year)

SURVEY 

NUMBER HP Hrs/Year Diesel

Natural 

Gas N0x VOC CO PM

153 210 1095 1 Tier 1 2272 329 2795 132

Tons/Year 1.14 0.164 1.40 0.0658
APPENDIX E

________________________________________________________________

Emission Impacts
Final Staff Report for Proposed Amended Rule 1110.2

Appendix E E-1 May 2005

EMISSION REDUCTIONS FOR AGRICULATURAL ENGINES. 

NOTE: Estimated emission reductions are double the figures below per the assumptions in the 

Emissions Inventory section of the staff report..

WELL / WATER PUMPS

EMISSION REDUCTIONS WITH 

CONTROLS (Tons/Year)

SURVEY 

NUMBER

Well/Water 

Pump 

Stationary Diesel

Natural 

Gas

HP 

Stationary

Operating 

Hours/Year 

Stationary

Diesel 

Pre-1996 

mfg date?

Natural 

Gas with 

controls?

CONTROL 

TECHNOLOGY N0x CO VOC PM

28 1 1 465 3000 Yes Electrification 13.98 3.03 1.1185 0.9974

28 1 1 330 3000 Yes Electrification 9.92 2.15 0.7937 0.7079

28 1 1 227 3000 Yes Electrification 6.83 1.48 0.5460 0.4869

28 1 1 145 3000 No Electrification 2.64 4.44 0.0353 0.0233

85 1 1 60 1460 ? NSCR 0.48 0.00 0.0000 0.0000

85 1 1 150 1460 ? NSCR 1.21 0.00 0.0000 0.0000

106 1 1 100 270 No NSCR 0.15 0.00 0.0000 0.0000

339 1 1 175 3600 ? Electrification 3.82 6.43 0.0512 0.0338

471 1 1 200 4320 No Electrification 5.24 8.82 0.0702 0.0463

471 1 1 200 4320 No Electrification 5.24 8.82 0.0702 0.0463

471 1 1 250 4320 No Electrification 6.55 11.02 0.0877 0.0579

TOTALS 56.05 46.19 2.7728 2.3999
Final Staff Report for Proposed Amended Rule 1110.2

Appendix E E-2 May 2005

IRRIGATION PUMPS

EMISSION REDUCTIONS WITH CONTROLS 

(Tons/Year)

SURVEY 

NUMBER

Irrigation 

Pump 

Stationary Diesel

Natural 

Gas

HP 

Stationary

Operating 

Hours/Year 

Stationary

Diesel 

Pre-1996 

mfg date?

Natural 

Gas with 

controls?

CONTROL 

TECHNOLOGY N0x CO VOC PM

24 1 1 150 300 ? NSCR 0.25 0.00 0.0000 0.0000

54 1 1 150 600 ?

SI Engine + 

NSCR 0.89 0.15 0.0620 0.0595

299 1 1 60 438 No(2004)

SI Engine + 

NSCR 0.08 0.04 0.0087 0.0042

334 1 1 75 1600 Yes Electrification 1.20 0.26 0.0962 0.0858

334 1 1 75 1600 Yes Electrification 1.20 0.26 0.0962 0.0858

334 1 1 75 1600 Yes Electrification 1.20 0.26 0.0962 0.0858

349 1 1 300 3000 Yes Electrification 9.02 1.95 0.7216 0.6435

351 1 1 75 364 No NSCR 0.15 0.00 0.0000 0.0000

TOTALS 13.99 2.93 1.0809 0.9647

EMISSION REDUCTIONS WITH CONTROLS 

(Tons/Year)

SURVEY 

NUMBER

ENGINE 

Other 

Stationary Diesel

Natural 

Gas

HP 

Stationary

Operating 

Hours/Year 

Stationary

Diesel 

Pre-1996 

mfg date?

Natural 

Gas with 

controls?

CONTROL 

TECHNOLOGY N0x CO VOC PM

153 1 1 210 1095 No(1998)

SI Engine + 

NSCR 1.11 0.39 0.1386 0.0535

TOTALS 1.11 0.39 0.1386 0.0535

GRAND 

TOTAL 

EMISSION 

REDUCTIONS 71.16 49.51 3.9922 3.4181
Final Staff Report for Proposed Amended Rule 1110.2

Appendix E E-3 May 2005

Notes: The following basis and assumptions were used in determining the emission reductions for agricultural engines.

Baseline emissions are the uncontrolled values (U.S. EPA, AP-42) or the required value (USEPA Tier), whichever is lower.

 Ratio of NOx:VOC g/bhp-hr for Tier 2 diesel engines assumed same as Tier 1 diesel engines.

 Ratio of NOx:VOC g/bhp-hr for Tier 3 diesel engines assumed same as Tier 4 diesel engines.

 Ratio of NOx:VOC g/bhp-hr for certified SI engines assumed same as for uncontrolled SI engines.

Electrification of SI engine assumes the baseline energy source is natural gas (based on AQMD survey of agricultural facilities).

LEC or PSC is assumed 80% effective on NOx (CARB RACT/BARCT Determination), and it is assumed that oxidation catalyst can meet the amended

rule limits on CO and VOC.

 Diesel PM assumed to be .0022 lb/hp-hr for Tier 0 (AP-42, Table 3.3-1) and required values for Tier 1 and above (dependent on hp of engine).

Assumed approx half SI engines and 80% of the diesel engines would be electrified and sites that have most hp and most hrs/yr operation

would be most likely to be electrified.
APPENDIX F

________________________________________________________________

Public Comments and Responses
Final Staff Report for Proposed Amended Rule 1110.2

Appendix F F-1 May 2005

Comments and Responses

Comments Received at the February 1, 2005 Public Workshop

The February 1 workshop and documents that were released prior to and at the time of 

the workshop covered both Phase I and Phase II of the proposed amended Rule (PAR) 

1110.2 and proposed rescission of Rule 1110.1. The Phase I rule amendments will 

primarily address agricultural engines and other minor amendments. Phase II 

amendments of Rule 1110.2 will address other issues such as improving the compliance 

of engines, emission limit changes, and distributed generation emission limits. 

Comments that were received during or in response to that workshop that are pertinent to 

Phase I of PAR 1110.2 and rescission of Rule 1110.1 are presented and responded to 

here. Comments that were received during or in response to the February 1 workshop 

that are pertinent to Phase II of PAR 1110.2 will be presented and responded to in 

another staff report to be released later.

Julia Lester, Environ International, on behalf of California Farm Bureaus 

Federation

Comment: The compliance date in the draft PAR is too early to allow the agricultural 

community to take advantage of some of the goals stated in the Agricultural Working 

Group and SB700. There is only a year and a half for industry and the agricultural 

community to comply, and really only half a year to make decisions because of the 

permitting requirements in the rule. The initial Rule 1110.2 allowed more than nine years 

to electrify and more than three years to add emission controls. The draft PAR is far 

more burdensome on the agricultural community than it was on other affected sources. 

Also, the proposed compliance schedule is not consistent with the Carl Moyer program or 

AB923, both of which start in 2006. The agricultural community would therefore not 

have the ability to understand these programs and decide whether or not to utilize them 

until after some initial permitting is required.

Response: Because new guidelines from CARB may not be ready in time to assure that 

agricultural facilities can qualify for state funding to comply with the rule by the 

originally proposed date of January 1, 2007, staff is proposing to extend the date to 

January July 1, 2008 for older engines and January 1, 2010 for newer engines.

Comment: The draft PAR requires permits for existing and modified engines regardless 

of farm size. This is inconsistent with Rule 219. Under SB700, farms under half the 

major source threshold cannot be permitted unless there are a variety of findings. There 

is no indication in the draft PAR of whether or not new engines need permits. It is 

recommended that the language requiring permits for existing engines be removed so that 

permit requirements for all engines will be governed by Rule 219.

Response: Rule 1110.2 does not supersede exemptions from permits in Rule 219. The 

proposed permit requirement in subparagraph (e)(21)(A) only applies to engines that are 

not exempt per Rule 219. However, staff is recommending that the Board make the 

findings necessary before amending Rule 219 to require permits for all agricultural 

engines subject to Rule 1110.2. 
Final Staff Report for Proposed Amended Rule 1110.2

Appendix F F-2 May 2005

Comment: In that the draft PAR requires records of fuel usage, will meters be required 

or will records suffice?

Response: Records such as purchase receipts and records of deliveries should be 

adequate.

Comment: The socio-economic analysis should account for the type and condition of 

the engines. Most are pre-1996 diesels, which will have to be replaced, re-powered or 

electrified. Replacement with SI engine should include the cost of compliance with Rule 

461.

Response: AQMD is gathering information on the number, size, and type of engines that 

exist at agricultural facilities in the region, and the socio-economic analysis will be based 

on this information. The information received to date does indeed indicate that most 

agricultural engines are relatively old and uncontrolled. If a facility chooses not to 

repower or replace a diesel engine with an electric motor or a natural gas engine, staff is 

assuming that it would be replaced by a propane-fueled engine. Therefore, it does not 

seem likely that compliance with the draft PAR would trigger any Rule 461 requirements

Comment: The agricultural community requests a presentation at the next working 

group meeting of the cost-effectiveness information and analysis as it stands at that time.

Response: Staff has complied with this request at the Working Group meeting held 

March 10, 2005.

Comment: The agricultural community would like information regarding the projected 

total cost impact of the draft PAR on the agricultural community.

Response: The staff report and socio-economic analysis study will address this impact.

William Pearce, Boeing Co.

Comment: For RECLAIM facilities, quarterly recordkeeping is preferable to monthly 

recordkeeping since quarterly recordkeeping is already done for RECLAIM.

Response: Staff agreed with this suggestion and revised the PAR to allow a quarterly 

engine log for an engine that is subject to Regulation XX and listed as a Process Unit on 

the facility permit.

Bruce Scott, Agricultural Operator

Comment: Based on past experience, to qualify for grant funds that are available, 

farmers must invest typically $10,000 to $20,000 for an engineering feasibility study.

Response: The Carl Moyer Program does not require the applicant to perform or submit 

an engineering feasibility study. Although the guidelines for the AB923 grant process 

have not yet been developed, it is reasonable to assume that they similarly will not 

require an engineering feasibility study. AQMD has previously funded diesel pump 

replacements with electric motors where operators did not have to pay for a study.

Comment: Conversion of diesel pumps to electric pumps will make sense in many 

cases; however, farmers are concerned about the reliability of the grid. 

Response: Southern California Edison data from the 10-year period ending with 2001, 

show that the maximum power interruption experienced by the average SCE customer 
Final Staff Report for Proposed Amended Rule 1110.2

Appendix F F-3 May 2005

during that period was 144 minutes in one year. It therefore seems unlikely that power 

interruptions will have a significant impact on the amount of water pumped when pumps 

are operating 24/7 or over extended periods of time.

Comment: The cost-effectiveness calculations should not assume year-round operation. 

In some cases, pumping is needed 24/7 during summer and not at all during the 

remainder of the year.

Response: Staff examined the effect on the cost-effectiveness results for electrification 

of assuming that all pumping occurs in SCE’s summer rate season as opposed to being 

spread throughout the entire year. It was found that cost-effectiveness actually improves 

due to the lack of demand charges in months when pumping does not occur.

Terry Ahn, Orange County Sanitation District

Comment: Emission limits in Rule 1110.2 should be stated in g/bhp-hr rather than 

concentration limits because the concern should be with mass emissions rather than 

concentrations.

Response: Staff agrees that work-specific mass emissions such as g/bhp-hr are ideally a 

better way to state the amount of pollution being caused by the engine. However, 

determination of g/bhp-hr requires, in addition to measurement of the pollutant 

concentration, a determination of the engine efficiency and mass emissions from the 

engine as well as some fairly complicated calculations. Staff believes that the potential 

for error in this process is so great that it outweighs the benefit of using the work-specific 

limits.

Tim French, Engine Manufacturers Association

Comment: The tighter restriction on use of portable generators amounts to essentially a 

ban on portable generators and appears to include generators driven by SI engines as well 

as portable diesel generators. This goes beyond CARB’s restriction on use of portable 

generators, which is limited to portable diesel generators.

Response: CARB’s restriction on portable generators is not limited to diesel generators; 

it includes SI engine-driven generators as well. The restriction is not a total ban. It 

prohibits use of portable generators for non-emergency power supplied to a facility or to 

the grid but does not restrict their use where portable power is genuinely needed such as 

for portable rock crushers, portable lighting, energy emergency backup to grid power, etc.

Written Comments Received Following the February 1, 2005 Public Workshop

This section summarizes written comments that were received from the public following 

the February 1 public workshop. Written comments that duplicate other written 

comments or comments that were received directly at the workshop are not repeated. 

Again, only comments that pertain to Phase I of the proposed rule amendments are 

documented here. Written comments that pertain to Phase II will be documented in a 

later staff report.

Mike Bukantz, GE Energy

Comment: PAR (d)(2)(B) appears to prohibit the use of portable engines to provide 

power at virtually any stationary source. Perhaps it is the District’s intention to clarify 
Final Staff Report for Proposed Amended Rule 1110.2

Appendix F F-4 May 2005

that PERP registrations are not valid for the purpose of providing power to a stationary 

source. However, so long as portable equipment can meet emission standards equivalent 

to BACT (including the statewide DG standards), we feel that the use of this equipment 

should continue to be allowed.

Response: Staff agreed with this suggestion and modified paragraph (d)(2) to exempt a 

portable engine that meets BACT, and also meets all requirements of the rule, from the 

requirements of that paragraph.

Ed Torres, Orange County Sanitation District

Comment: Regarding PAR 1110.2’s definition of “emergency standby engine” (c)(3), it 

may be necessary to operate an emergency standby engine under many different 

situations, not just “while the primary power supply is under repair”. For example, 

during heavy rainstorms, it may become necessary to operate pumps, using all available 

primary power to accommodate excessive peak water flow. In this case additional power 

needs of the facility may be temporarily satisfied by means of emergency generators. 

Therefore, we propose to replace “under repair” with “unavailable”.

Response: The current definition for emergency engines only includes engines that 

temporarily replace primary power during shortages or interruptions. It does not include 

engines that operate during peak loads that exceed the capacity of the normal primary 

power. Engines that provide primary power during peak loads must comply with Rule 

1110.2. 

Comment: It is not clear why VOC limit is expressed as “measured as carbon” instead 

of “measured as methane” in the current rule. Your own staff report refers to VOC 

measured as methane (pp. 13, 14).

Response: Since the rule limits are concentration limits, expressing measurement results 

“as methane” or “as carbon” makes no difference because each has only one carbon 

atom. Staff proposes to change the language in the rule from “as methane” to “as 

carbon” to avoid the implication that methane may be included in the measurement.

Comment: The language restricting the operation of portable generators(d)(2) seemingly 

contradicts all intentions of mere existence of portable engines as well as recently 

approved regulations for stationary Diesel engines. OCSD is conducting significant 

construction projects requiring temporary electrical power for scheduled activities. In 

addition, our field operation, such as pumping and line cleaning, require use of portable 

engines. Usage of stationary diesel engines for such purposes is mostly restricted by the 

recently adopted State regulations and SCAQMD Rule 1470 and providing temporary 

utility line is absolutely impractical. That is exactly the reason why OCSD and other 

publically owned treatment works purchase and maintain large fleets of portable engines. 

Severe restrictions on the portable engines usage established in paragraph (2) (B) would 

make many of our activities simply impossible. We suggest, therefore, eliminating the 

paragraph or make significant changes in its language (for example, eliminate the words 

“unforeseen” interruptions and “remote” operations and add “construction” operations.

Response: The PAR does not prohibit use of a portable generator to power portable 

equipment, as is generally the case at a construction site. It also does not prohibit the use 

of portable engines driving pumps or other equipment besides generators. Portable 
Final Staff Report for Proposed Amended Rule 1110.2

Appendix F F-5 May 2005

generators can also be used for scheduled maintenance and repair activities. The 

proposed rule amendment uses the same language as that recently adopted by CARB in 

their portable equipment registration rules.

Comment: Replacement of AQMD Method 25.3 by 25.1 in Table VIII may result in 

significant increase in the measured VOC concentration due to “positive interferences for 

low concentration of VOC (50 ppm) due to high levels of stack carbon dioxide and 

moisture” (SCAQMD Source Test Manual, Chapter VI, March 2000). In addition, 

utilizing dry ice traps (-62oC) instead of melting ice (0oC) together with other, more 

complicated equipment, makes the testing significantly more expensive and may result in 

artificially higher results of testing. We suggest making SCAQMD Method 25.3 to 

remain a method of choice for VOC measurement.

Response: Method 25.3 is not being replaced by AQMD Method 25.1. Current Rule 

1110.2 specifies either USEPA Method 25 or AQMD Method 25.1. The version of PAR 

1110.2 that was distributed at the workshop eliminated the option of USEPA Method 25 

and specified only AQMD Method 25.1. Staff agreed, however, that AQMD Method 

25.3 may be a useful alternative if the expected VOC concentration is below 50 ppmvd 

and therefore added this alternative to the PAR.

Charles Humphrey, Jr., Southern California Gas Co. and San Diego Gas & Electric 

Co.

Comment: The compliance schedule required by Section (e) is unrealistic, particularly 

in light of the District’s inability to process even simple permit applications for more 

complex RECLAIM and Title V facilities within the 180 day time frame required by law. 

The following changes should be made in section (e) to address this problem for this 

aspect of the rule:

(e) (1) (A) (ii) By September 30, 2006, or within 90 days of the issuance of a final 

Permit to Construct (PTC), initiate engine and control equipment installation; and

(e) (1) (A) (iii) By January 1, 2007, or within 180 days of the issuance of a final 

PTC, complete source testing and have the engines in compliance with the rule.

It should be stressed that for a facility that triggers NSR (e.g. engine replacement option) 

or for larger, more complex installations, these time frames are not even remotely 

feasible and the District still needs to address those cases.

Response: Staff has revised the draft rule to allow more time if a permit is delayed.

Joseph L. Suchecki, Engine Manufacturers Association

Comment: Farmers may have no viable option but to use diesel-fueled compression 

ignition engines because power is needed in very remote locations. In such locations, 

alternative fuels may not be suitable and it may be cost-prohibitive to run electrical power 

transmission lines to the location. In such situations, where diesel-fueled engines are the 

only available option, AQMD should establish appropriate and reasonable emissions 

standards that will allow the continued operations of these engines. The requirements 

and standards applicable to agricultural operations in Rule 1110.2 should not be so 

stringent and cumbersome as to force farmers to abandon their operations or be forced 

out of business. 
Final Staff Report for Proposed Amended Rule 1110.2

Appendix F F-6 May 2005

Response: Although electrification may not be feasible for all agricultural diesel 

engines, conversion to a spark ignition engine using a clean fuel should be feasible in all 

cases and is not cost prohibitive. In fact, natural gas and propane are less expensive than 

diesel fuel per unit of heat input.

Cynthia L. Cory, California Farm Bureau Federation

Comment: Stationary agricultural engines should be allowed to at least January 1, 2010 

to comply with PAR 1110.2 because: 1) other engines were given up to 9 years to 

electrify and over 3 years to retrofit by the previous Rule 1110.2; 2) funding from the 

Agricultural Assistance Fund (AAF) may not be available in time for a January 1, 2008 

compliance date; 3) the proposed San Joaquin Valley Air Pollution Control District 

(SJVAPCD) Rule 4702 would not require older engines to comply until 2010 and newer 

engines to even later; 4) the January 1, 2008 compliance date doesn’t provide the 

minimum compliance period required by AB923 (3 years from date of adoption); and 5) 

funding programs tend to be significantly oversubscribed. 

Response: 1) When it was originally adopted, Rule 1110.2 was applicable to thousands 

of engines operated by a variety of different industries that were required to make 

significant capital expenditures to comply with the rule. This does not hold true for the 

stationary agricultural engines. There are a relatively small number of stationary 

agricultural engines, and there are public funds available to pay for most of the capital 

costs. Therefore, the request for extension until 2010 is unwarranted. 2) Staff expects 

that the awards will be made in March 2006 based on current Carl Moyer guidelines and 

in March 2007 based on the AAF guidelines being developed, which should provide 

adequate time. To assure that there is adequate time, staff is proposing to extend the final 

compliance date for older engines to July 1, 2008. 3) While commenting on 

SJVAPCD’s SIP obligation and control strategy choices is beyond the scope of this 

analysis, AQMD, because of its extreme non-attainment status, is obliged to implement 

all feasible measures as expeditiously as possible to make timely progress towards 

attainment of the ambient air quality standards. 4) AB923 sets no minimum time for 

compliance dates; it does set maximum times for funding. 5) AQMD has initially set 

aside $4 million for 2005-2006 for AAF. AQMD could consider additional funding for 

the AAF for 2007 if the need exists. 

Comment: There are stationary agricultural engines driving pumps that are remote, are 

often low use, and cannot be replaced by an electric pump. They should be exempt from 

the emission limits and source testing requirements of Rule 1110.2 if they are replaced by 

a certified Tier 3 diesel engine or a certified non-road, spark-ignited engine. 

Response: Although there are a few CARB-certified, spark-ignited (SI), off-road 

engines that can meet the emission limits of Rule 1110.2, in general Tier III diesels and 

CARB certified SI engines emit up to four times as much NOx as allowed by Rule 

1110.2. However, the proposed exemption paragraph (h)(12) will allow operators of 

engines that are rejected for electrification by the electric utility or can not receive 

funding help from the Agricultural Assistance Fund to comply by installing a Tier 4 

diesel by 2014.
Final Staff Report for Proposed Amended Rule 1110.2

Appendix F F-7 May 2005

Comment: Proposed subparagraph (d)(1)(D) is unnecessary and punitive for stationary 

agricultural engines, and should be removed. Clause (i), which requires BACT for new, 

permitted ag engines, is redundant. Clause (ii), which requires emission limits equivalent 

to existing BACT for new unpermitted ag engines, sets more stringent standards for new 

ag engines than other engines. SB700 protects ag engines from burdensome regulations. 

Also, permits should not be required for engines at farms below 50% of the major source 

thresholds.

Response: Clause (d)(1)(D)(i) may be redundant, but it serves to remind agricultural 

facilities of the applicability of AQMD’s New Source Review rules. It is AQMD’s intent 

to require, in accordance with SB700, stationary ag engines to comply with the same 

permitting and emission requirements as non-agricultural engines. Staff will recommend 

the Board to direct staff to start the rulemaking necessary to accomplish this. Until 

AQMD permitting rules are revised to require permits for all stationary ag engines over 

50 hp, clause (d)(1)(D)(ii) is needed to assure that new, stationary ag engines meet the 

same emission requirements as new, non-agricultural engines.

Comment: AQMD should exempt replacement engines from BACT.

Response: AQMD’s New Source Review (NSR) regulations require non-identical 

replacement equipment to have BACT. The NSR regulations do, however, exempt 

functionally equivalent replacements from modeling and emission offsets. Tier 4 diesel 

engines installed pursuant to the limited exemption of paragraph (h)(12) will be 

considered to comply with BACT.

Comment: The staff report should clarify that portable engines are not subject to the 

emission limits of subdivision (d). 

Response: The staff report does say that the exemption for nonroad engines does mean 

that portable engines do not have to comply with the emission limits in the rule. 

Comment: The applicability notification required in subparagraph (e)(1)(A) should: be 

the basis for an outreach program to inform agricultural facilities of funding 

opportunities; use a standardized form; and not include the requirement to notify AQMD 

of the expected means of compliance. 

Response: Staff agrees with your first two suggestions, and would like to work with the 

California Farm Bureau Federation to make that happen. The requirement to include the 

expected means of compliance, will not be binding on the agricultural facility, but it will 

help AQMD anticipate the types of projects, permitting requirements and funding needs 

for agricultural facilities.

Comment: The cost-effectiveness analysis for electrification should take into account 

only the existing electric rates, not the reduced rates proposed by Southern California 

Edison Co. but not yet approved by the California Public Utilities Commission.
Final Staff Report for Proposed Amended Rule 1110.2

Appendix F F-8 May 2005

Response: The cost-effectiveness analysis for electrifying natural gas engines does use 

the current electric rates, and it shows that electrification, even with the higher rates, is 

still very cost-effective.

Comment: The board resolution should require AQMD staff to report yearly to the 

Stationary Source Committed whether any qualified farms will not be able to take 

advantage of funding programs and if not, the reasons why.

Response: Providing periodic status reports to the Stationary Source Committee on rule 

implementation and related issues, including funding, is a good suggestion. Staff intends 

to incorporate the suggestion as part of the adopting resolution.

Comment: Notwithstanding our first recommendation, the compliance deadline for 

existing Tier 2 or Tier 3 engines should be consistent with SJVAPCD PR 4702, e.g. 

would not have to be replaced for up to 10 years after their purchase date. This only 

represents a few local agricultural engines, at most. As noted in our comments on the 

cost-effectiveness analysis below, owners of these engines may not qualify for funding, 

based on the cost-effectiveness thresholds in the funding programs. We believe that 

owners who recently upgraded their engines, thus reducing current levels of pollution, 

should be allowed greater time to replace those engines.

Response: Staff’s cost-effectiveness analysis indicates that, in most instances, further 

reductions from these newer engines are feasible and cost-effective. However, 

recognizing that these engines are lesser polluting compared to Tier 1 and Tier 0 engines, 

staff added an additional extension of two years to the compliance dates for Tier 2 and 

Tier 3 diesel engines and certified SI engines (i.e., final compliance date of January 1, 

2010).

Comment: The recordkeeping requirements for portable engines include a monthly log 

of total hours of operation, type of fuel, and fuel consumption. An outreach effort is 

needed to inform farmers of this new requirement.

We recommend that the compliance date for portable engine reporting requirements be 

moved to January 1, 2006 and that the Board resolution include an outreach program to 

farmers concerning the new rule requirements.

Response: Staff agreed with this suggestion and made the suggested change to the PAR 

compliance date for portable engine recordkeeping. Staff will work with the farm 

Bureaus to inform farmers of the new requirements.

Comment: Because most agricultural engines are pre-1994 engines (e.g. Tier 0), 

replacing them will obviously produce more emission reductions than replacing newer 

engines. This is important because the Carl Moyer and AB 923 funding programs have 

cost-effectiveness thresholds of $13,600 per ton of NOx reduced. As such, costeffectiveness should also be reported per ton of NOx reduced. As shown in the 

SCAQMD staff’s cost-effectiveness spreadsheet, replacing new engines (which costs 

relatively the same as replacing an older engine) is relatively less cost-effective than 

replacing older engines. In some cases, the cost-effectiveness will be above the threshold 
Final Staff Report for Proposed Amended Rule 1110.2

Appendix F F-9 May 2005

used by the funding programs. This should be reflected in the socioeconomic analysis, 

particularly as it relates to the cost impacts.

Response: The initial cost-effectiveness analysis, as presented at the February 1, 2005 

public workshop, assumed that all capital costs would be paid by Carl Moyer or AB923 

grant funds. Staff was later informed that the AB923 funds will be capped at a maximum 

cost-effectiveness of $13,600 per avoided ton of NOx and VOC emissions and PM 

emissions multiplied by ten. The revised cost-effectiveness analysis and socioeconomic 

analysis take this into account.was revised to reflect this capping criterion.

Comment: the cost-effectiveness should not be calculated with the incentives; the cost 

to reduce a given amount of pollution is the same regardless of the source of funds. It 

would be more appropriate to assess the impact of incentives on the direct costs to the 

farmers, such as in the industry impact analysis.

Response: The intent of the cost-effectiveness analysis is to determine whether or not 

the proposed rule amendments are financially too burdensome on farmers. The overall 

cost to society is not an issue since society has already decided to contribute the grant 

funds via its representative form of government.

Comment: The socioeconomic analysis should take into account the actual in-use 

engines on local farms, which are overwhelmingly pre-1995 diesel engines. The cost and 

socioeconomic analysis should include absolute costs, with and without incentives, not 

just cost-effectiveness.

Response: The cost-effectiveness analysis does consider pre-1995 diesel engines. The 

cost-effectiveness presentation in the staff report was revised to show absolute costs with 

and without incentives.

Comment: The definition of agricultural stationary engines in PAR 1110.2 is confusing 

and not consistent with SB 700. The last sentence should be deleted.

Response: Staff believes that the referenced sentence is helpful in clarifying that, for 

purposes of the rule, agricultural engines are limited to those used directly in the growing, 

raising and harvesting of agricultural products and not those used in processing or 

distribution of those products.