SAN JOAQUIN VALLEY AIR POLLUTION CONTROL DISTRICT. Appendix A: Comments and Responses June 22, 2011 APPENDIX A

Transcription

1 APPENDIX A Summary of Written Comments on Draft Rule 4702 and District Responses June 22, 2011 A - 1

2 This page intentionally blank. A - 2

3 SUMMARY OF SIGNIFICANT COMMENTS FOR DRAFT RULE 4702 DATED SEPTEMBER 9, 2010 EPA REGION IX STAFF COMMENTS 1. COMMENT: SJVUAPCD should perform a thorough analysis to ensure Clean Air Act (CAA) section 172(c)(1) and 182(a)(2)(A) requirements for all reasonably available controls (RACT) are met and should examine the more protective requirements adopted by the South Coast Air Quality Management District (SCAQMD). RESPONSE: District staff believes that the existing Rule 4702 emission limits meet CAA RACT requirements and have added a discussion to the draft staff report. This amendment further strengthens Rule 4702 and goes beyond RACT. Staff has reviewed similar control standards in other air districts during the development of this rule. In regards to the SCAQMD limits, it is important to note that many engines in their jurisdiction are part of the RECLAIM program. This program allows operators reduce the equivalent quantity of emissions from sources other than engines rather than having the engine directly comply with the South Coast AQMD s engine rule. Due to the RECLAIM program, the lower South Coast AQMD NOx limit may not be actually achieved-in-practice for many classes of engines. 2. COMMENT: Table 2 limits NOx emissions from cyclic loaded, field gas fueled engines to 25 ppm. Further strengthen this requirement or explain why that is not appropriate given the 11 ppm limit for similar engines in SCAQMD Rule , Section (d)(1)(b) and for most other non-agricultural spark-ignited engines in the SJVUAPCD. RESPONSE: According to SCAQMD staff, there are 11 engines fired on field gas fuel in crude oil production facilities that drive generators to produce electricity for use by electric oil well pumps. These field-gas-fueled engines are not cyclic loaded to the extent of the directly-powered oil wells engines found in the Valley. Due the variability of field gases heat content and the cyclic mode of operation of Valley s crude oil well pumping engines, a NOx limit lower than 50 ppmv is not considered to be either technologically or economically feasible for this cyclic loaded and a NOx limit lower than 50 ppmv is not technologically feasible for waste-gas fueled engines. Therefore we are proposing 50 ppmv for these categories and additional language has been added to the draft staff report. A - 3

4 3. COMMENT: The draft rule would reduce limits for rich-burn engines in nonagricultural operations from 25 to 11 ppmv. The emission limits for agricultural operations (AO) rich-burn engines are not being changed. More fully demonstrate why a lower limit is not appropriate for AO engines and describe the criteria to determine when more stringent requirements would be appropriate RESPONSE: AO engines have just recently been required to comply with Rule 4702; the current emission limits have compliance dates from January 2009 through January By comparison, non-ao engine emission limits were first adopted in 2003; meaning that operators with non-ao engines have had an opportunity to get a return on their investment. In order to give agricultural operators some return on their capital investment, it would be imprudent to impose new limits for agricultural engines at this time. The control systems installed on AO engines included a 3-way catalytic converter, an air/fuel ratio controller, and an oxygen sensor. AO engines are typically installed in remote locations, the gas supply has fluctuating pressures, and operations are unattended. The District is still evaluating the effects and other technical operational problems because of the conditions they were installed make it more difficult to constantly monitor the emissions level during day-to-day operation of the engines. 4. COMMENT: SJVUAPCD is adding new requirements to limit and test SOx emissions from engines, partly because of the improved understanding of the role of SOx emissions on the area s significant PM2.5 problems. Why are agricultural engines exempted from these requirements, particularly since compliance is based largely on use of low-sulfur fuel, which widely available throughout the state? RESPONSE: Most agricultural irrigation pumping engines are already fired on California reformulated diesel fuel or PUC-quality natural gas so there would be little practical benefit from opening these limits at this time. This category has recently come into compliance with the 2009 NOx emission limits and is considered to be RACT. The District may reevaluate the long-term effectiveness of the currently installed NOx emission control system along with SOx scrubbers under future attainment plan actions. 5. COMMENT: Draft language would allow sources to pay fees in lieu of complying with emission limits. Please demonstrate that these proposed revisions will not interfere with federal Clean Air Act RACT requirements. The existing submittal of Rule 4702 does not include all necessary details on how creditable emission reductions will be achieved. Thus, it is not appropriate to fully credit emission reductions for this rule without additional submitted materials. RESPONSE: As mentioned above, the existing rule requirements are considered to satisfy RACT, so existing engines will comply with CAA A - 4

5 requirements. The District is committed to working with the EPA to address concerns with respect to the Economic Incentive Program (EIP) guidance document and to collaboratively improve the success of the proposed program. The District understands and will ensure that the emissions reduction that will be funded by the annual fees must be surplus, quantifiable, enforceable, and permanent in order to claim such reduction for SIP creditable. Credit reductions will not be counted until achieved. 6. COMMENT: The District should take into consideration the condensable fraction of direct PM2.5 emissions per EPA's Fine Particulate Rule, 40 CFR 51 Subpart Z. RESPONSE: A discussion of condensable PM2.5 is now included as part of the staff report. See the draft staff report for details. ARB STAFF COMMENTS: No comments were received. STAKEHOLDER COMMENTS Association of California Water Agencies (ACWA) Bear Valley Community Services District (BVCSD) Chevron USA Inc. (CUSA) El Monte Dairy (EMD) Engine Manufacturers Association (EMA) EnviroTech Consultants, Inc. (ETC) Fresno/Clovis Regional Wastewater Reclamation Facility (RWRF) Golden Hills Community Services District (GHCSD) Kern Oil & Refining (KOR) Stallion Springs Community Services District (SSCSD) Tehachapi-Cummings County Water District (TCCWD) West Kern Water District (WKWD) Vintage Production California, LLC (VPC) Western Agricultural Processors (WAPA) Western States Petroleum Association (WSPA) 7. COMMENT: Section This sentence is vague in its meaning. Any IC engine powered mechanical device that could be powered by an electric motor, which includes almost all rotating equipment, would fall within this description. (ETC) RESPONSE: There are applications where an operator keeps both a fossilfueled engine and an electric motor to power a particular piece of equipment. The fossil-fuel fired engine is operated in place of an electric motor when the A - 5

6 cost of operating the fossil fuel engine is cheaper than the cost to operate an electrical motor. When fossil-fuel fired engines are used this way, it is called peak shaving. The intent of the current rule language is to not allow an engine used for peak shaving to be considered a low-use engine. No change to the existing language in Section is proposed. 8. COMMENT: The District has proposed to delete Section 4.4 which exempts from BACT and Offset requirements for replacement of an existing engine with a new engine capable of complying with Rule 4702 limits. The existing section should be retained since in some cases operators may wish to replace older existing engines with new engines to meet the very stringent Rule 4702 proposed limits. (WSPA, CUSA, ETC) RESPONSE: After conferring with the District s Permit Services Department, staff agrees with the commenter s justification. The existing Section 4.4 in Rule 4702 will be retained. Please see the Staff report for further discussion. 9. COMMENT: The rule should exempt IC engines that run less than 50 hours per year. The generators run less than 10 hours per year, including test runs. The PTO and operating fees are unrealistically high based on the very low usage of these dairy generators. (El Monte Dairy) RESPONSE: The requirement for a District Permit and annual permitting fees originates in other District rules so it would be inappropriate to include such an exemption in this rule. 10. COMMENT: The District has proposed to include a point-of-sale requirement for engines having a horsepower rating between 25 bhp to 50 bhp. It should be deleted or revised such that it does not extend to portable equipment, but only to stationary internal combustion engines. Since the NSPS standards requires all engines sold to meet the applicable NSPS and requires certification of the majority of small engines, federal regulations already restrict sales to compliant engines, so there is really no need for the District to establish such a requirement in their regulations. The District should eliminate the inclusion of the proposed requirements for engines rated at 25 to 50 bhp. Title V stakeholders are already capped on emission thresholds. These additional restrictions will negatively affect facilities operations and create unwarranted expense and workload in return for a minute additional emissions savings. (CUSA, WSPA, EMA, KOR, RWRF) RESPONSE: The draft requirement does not apply to portable engines since they are already currently exempt from Rule 4702 because they are subject to District Rule 2280 (Portable Equipment Registration) or the Statewide Portable Equipment Registration Program. The purpose of the draft requirement is to reduce emissions from this engine category through attrition of older, more- A - 6

7 polluting engines. It does not place additional requirements on engine manufacturers or on operators who purchase new engines. 11. COMMENT: If an older engine between 25 and 50 hp is shut down and sold, e.g., this provision would impose the NSPS emissions standards on the engine as if it were manufactured on the date of sale. Subjecting stakeholders to these strict standards will seriously impact the use of this family of engines. These engines commonly power small equipment and stripper oil type wells where electricity is not accessible and the proposed provision would like result in shutting down many of these wells, and curtailing domestic energy production. (ETC, KOR, VPC) RESPONSE: This provision regulates engines by attrition rather than requiring the operator to install additional emission control system on existing engines as is the case for engines greater than 50 bhp. Over time, the engines between 25 and 50 bhp will be replaced with the cleanest-burning engines available and the replacement happens at a time of the operator s choosing, since the operator elects when to replace a given engine. If there is no cleaner engine available, meaning that the federal emission limits haven t changed since the engine was manufactured, the engine can change hands and continue to operate within the Valley because the engine is the cleanest version available. Conversely, if there is a cleaner federal emission standard than the standard at the time the engine was manufactured, rather than continuing to have the older, dirtier engine continuing to operate, but at a different Valley location, the District is proposing that the older engine be retired. The draft requirement, as written, is a win-win situation for both operators and Valley air quality because it provides continuous air quality improvement through normal engine turnover as well as operator flexibility by allowing the operator, not the District, to determine when to replace an engine. 12. COMMENT: Rich-burn engines and lean-burn engines have different operating characteristics and the control technology available for reducing emission differs significantly. Both EPA and ARB have recognized this fundamental difference and have established different control requirements for each engine type. The draft emission limits should be based on engine type (rich-burn versus leanburn). (WSPA and CUSA) RESPONSE: The proposed emission limits that apply to both rich-burn and lean-burn engines are based on engine type, and both emission limits are technologically achievable based on source testing results. The fact that different control system would be required does not necessarily justify establishing different emission limits since the proposed technologies can both meet the 11 ppmv NOx limit for their intended application category. A - 7

8 13. COMMENT: Older engines that had been in operation for a few years are likely to require the redesign of the exhaust gas catalyst system and retrofit for new air to fuel ratio controllers. We believe that the proposed limit exceeds RACT/BARCT requirements and should be considered as an advanced emission reduction control technique and be designated as such in the proposed rule. (WSPA, CUSA) RESPONSE: The proposed NOx limit is based on the limit in South Coast Air Quality Management District Rule as well as the results from sources tests of engines located within the District that are equipped with suggested control systems. Based on the existing information, the control technology under consideration has been demonstrated to be feasible for retrofit applications to existing units and therefore meets the definition of BARCT. Actual BACT limits for new equipment are slightly lower. 14. COMMENT: Although certain engines with advanced air-fuel ratio controllers and fresh catalysts can be designed to meet the standards for all three pollutants under controlled conditions, it is unlikely that the standards can be met under inuse field conditions on a continuous basis. Packagers of stationary engine systems may be able to demonstrate compliance during source test under controlled condition, but environmental variation, variation in fuels and instruments, and changes to the catalyst bed over time are likely to create conditions where emissions will not be consistently maintained below the proposed standards. (EMA) RESPONSE: District staff is now proposing no change to the existing CO and VOC limits; this will allow operators to focus on achieving NOx reductions rather then lower CO or VOC from current limits. It is important to mention that Section of the rule requires source testing with the engine operating either at conditions representative of normal operations or conditions specified in the Permit-to-Operate. In other words, the test should be conducted over the range of conditions that engine is expected to operate and not just under controlled conditions. Actual field testing in the Valley have verified the limits are achievable in practice. 15. COMMENT: Include both a specific emission limit for NOx and CO as well as a percent reduction target. NOx emission control equipment can generally guarantee a nominal 90% NOx from an uncontrolled engine baseline. Recommend 70% reduction for CO, which is based on extensive analysis by U.S. EPA in setting standards for stationary internal combustion engines as part of their NESHAP for reciprocating internal combustion engines. Allow use of 90% control of emissions using AP42 emission factors for rich burn engines as the uncontrolled emission baseline. The 50 ppmv limit proposed for waste gas fueled engines is greater than 90% control based on this data. (EMA, ETC, WKWD) A - 8

9 RESPONSE: No change to the proposed 11 ppmv NOx limit for lean-burn engines is proposed since properly sized SCR technology is able to achieve this limit. The inclusion of a percentage reduction in earlier rule versions was based on the technology performance of early systems and should not be required with current designs. Staff continues to encourage stakeholders to submit their estimated compliance costs that would be helpful in refining the cost analysis. District staff has changed the previously proposed 500 ppmv CO limit to 2,000 ppmv, which is more technologically achievable given the fact that a more stringent 11 ppmv NOx limit is being established. 16. COMMENT: The proposed limits for cyclic loaded field gas fired engines would likely result in shut down of remaining units. Although there has been some success with three-way catalysts system, inconsistent exhaust temperatures hamper the activation of the catalyst and limit effectiveness. The promulgation of the current rule limits in 2006 resulted in shutting down many cyclic loaded engines because that could not meet these limits. (VPC and WSPA, CUSA) RESPONSE: District staff agrees with commentor about the technological feasibility of advanced controls on cyclic loaded engines. The NOx emission limit has been revised to 50 ppmv. See draft rule. 17. COMMENT: For gaseous-fired spark-ignited engines, the VOC emissions are heavily dependent on the composition of the fuel and the concentration of methane and ethane in the fuel. In many cases the hydrocarbon emissions from a gaseous-fueled engine will be dominated by methane and ethane. Rule 4702 should include VOC measurement methods that are referenced in the EPA NSPS for stationary engines. (EMA) RESPONSE: District staff agrees that methane and ethane, which are exempt compounds, should be excluded from the measurement result. Staff has modified the language in the test methods section to specify that ethane and methane shall be excluded from the result of the measurement, similar to the test method provision in SCAQMD Rule COMMENT: The District has proposed to reduce the CO emission limit from 2000 ppmv to 500 ppmv. The commentor is opposed the establishment of lower CO limit given the fact that the Valley Air Basin is in attainment of the state and federal CO standards. Maintain the current 2,000 ppmv limit and as an option include an 80% control efficiency limit. (WSPA, KOR, and CUSA) RESPONSE: Staff is now proposing to retain the current limit of 2,000 ppmv CO. Please see the response to Comment 14. A - 9

10 19. COMMENT: SOx from spark-ignited engines are inherently low. SOx compression-ignited engines operating on ultra-low sulfur fuel are also very low. The level of sulfur emissions depends on the sulfur content of the fuel and lubricating oil. Therefore, thee most appropriate and practical approach to reducing SOx emissions is to control sulfur levels in the fuel. There is no known cost effective and available control technology to further reduce sulfur emissions from compression-ignited engines. PM emissions are not an issue for SI engines and so no additional controls are required. (EMA) RESPONSE: District staff agrees with commenter and has included fuel types and sulfur requirements in the draft rule as the method to control SOx emissions rather than add-on controls for Sox emissions. The specified fuel types and corresponding sulfur contents are currently being used to operate the engines, and therefore would already be in compliance with the proposed SOx requirements. 20. COMMENT: The inclusion of a provision that allows payment of annual fees in lieu complying with the advanced emission control requirements of the rule is appropriate given that the limits go well beyond RACT/BARCT, and is allowed by the federal Clean Air Act and the California Clean Air Act. (WSPA, CUSA) RESPONSE: District staff thanks the commentors for their support. 21. COMMENT: To avoid potential confusion and to ensure consistency with the language contained within Section 5.6, the title of Section 5.6 should revised to delete the word NOx. (CUSA) RESPONSE: The title in Section 5.6 would not be changed. The annual fee payment is intended as an alternative option to comply with the proposed NOx limit, but not for CO and VOC. The current CO and VOC limits in the rule are not proposed to be changed. 22. COMMENT: The differential NOx emissions that are emitted into the atmosphere above the standard are the emissions of concern, and the fee should not include the NOx emissions level up to the standard, which in fact would be emitted by all similar sources if the proposed changes go forward. (EMA) RESPONSE: Staff believes that the alternative compliance option to meet the proposed NOx limit by paying annual fees to the District would provide operators with the flexibility of weighing the most economical means that they could comply with the rule. The fees paid to the District will be used by the District to fund air quality projects in order to obtain an equivalent or greater reductions at lower costs than if the engines would be retrofitted with controls to comply with the rule s NOx emission limit. The emissions fee is a compliance option but it is not designed to be an equivalent compliance option. Therefore, the fee is not based only on the difference between actual emissions and the rule limits. The fee A - 10

11 calculations language does, however, use the Permit-to-Operate emission limit so adding a partial control and reducing the permitted emission factor would result in a lower emissions fee. 23. COMMENT: The District is proposing to delete the existing Alternative Emissions Control Plan (AECP). The option of participating in an AECP should be retained since it would allow operators to comply with proposed emission limits in the most effective manner. (WSPA, CUSA) RESPONSE: District staff has reconsidered the previous proposal and the draft rule retains the existing AECP in the rule in order to provide operators with additional flexibility to comply with the proposed rule emission limits. 24. COMMENT: Proposed Sections 5.8, 6.1, and 7.7 require updating and submitting Emission Control Plan and Inspection and Maintenance Plans. In some cases, complying with the proposed emission limits will not trigger variations in existing APCO-approved plans. We recommended that language be added these sections stating that the plans need not be updated and resubmitted if there are no changes to the existing APCO-approved approved plans. (KOR, VPC) RESPONSE: District staff agrees with commentors. Please see the draft rule. 25. COMMENT: The compliance schedule in Section 7.7 requires the submittal of an application for an ATC. For many permitted engines, compliance with the provisions of this rule will not require any physical changes to the engine or the permitted control device; the ATC will be solely to change the emission limits. In this case, the permits should be revised administratively without an application and the associated fees. If the engine on a currently approved Emission Control Plan has not changed model, horsepower, or type of emission control, then no ATC should be required and the District should modify the existing permit with the new limits as an administrative change. (KOR, VPC) RESPONSE: The District has an existing written policy that requires the submission of an application for Authority-to-Construct for revising emission limits to lower values to comply with the prohibitory rules. Therefore, the proposed Section 7.7 requirements would not be changed. However, the District is committed to the efficient and streamlined processing of administrative ATC applications and will work with industry to explore the potential for streamlining the processing of applications. 26. COMMENT: We recommend that if an operator has an agreement to electrify, the compliance schedule for each engine subject to the agreement would be extended to January 1, Extending the compliance schedule would over the long-term create far greater emission reductions than complying with the proposed rule limits by It is not practicable to convert all engines at sources with multiple engines within one year. Staged compliance is critical to A - 11

12 the successful retrofit of these engines. Payment of fees in lieu of compliance could be used to allow time to perform the retrofits. However, the fees are expensive, and sources are already faced with reduced revenues and increased costs. The District and sources would be better served if instead of fees paid directly to the District, the source were allowed to use these funds to retrofit engines over several years. (ETC) RESPONSE: The District is committed to achieving attainment of the federal ozone standards and the federal PM2.5 standards as expeditiously as possible. The emissions reduction from establishing more effective emission limits for internal combustion engines is a critical element of the District s attainment strategy. Although there is no commitment for this control measure, we do have commitments to provide additional emission reductions to satisfy the black box commitments. Excessively extended schedules will hamper the District s goal of reducing emissions in a timely manner. The compliance schedule of 2014 is needed to attain the federal health-based ambient air quality standards. The rule does allow operators of multiple units to phase-in their compliance. The provision for payment of annual emission fees in lieu of retrofitting engines allows operators the flexibility to stage the installation of controls on some units without sacrificing the emission reductions needed to expeditiously attain the ambient air quality standard. 27. COMMENT: Information and locations of SCRs that have been installed and achieved the limits proposed for lean-burn engines has not been provided. Staff should provide this information so that it can be examined as a viable option showing proven technology. Exhaust temperature of our lean-burn engines are higher than what you have stated in the staff report. The District should allow lean-burn engines to operate at the same 50 ppmv NOx limit as rich-burn waste gas, and 20 ppmv limit for rich-burn engines. CO should remain at 2,000 ppmv for rich burn engines and 1,300 ppmv for lean-burn engines in order to have flexibility to achieve lower NOx. (WKWD) RESPONSE: District staff has provided the commenter with a list of lean-burn engines equipped with SCR control system operating with the San Joaquin Valley. Since SCR control technology for lean-burn engines and NSCR for richburn engines are available to meet the proposed emission limits, District staff believes that there is no compelling reason to establish different NOx limit for lean-burn engines and rich-burn engines. District staff is now proposing 2,000 ppmv CO limit instead of the previously proposed 500 ppmv and no change to the current VOC limit of 250 ppmv in order to allow greater flexibility of achieving the proposed 11 ppmv NOx limit. A - 12

13 28. COMMENT: The District s Cost Effectiveness Analysis for control equipment retrofits underestimates the actual real-world costs incurred for compliance. For example, during Rule 4703 (Stationary Gas Turbines) workshops in 2007, the District estimated a capital investment of $400,000 to $900,000 to retrofit a 2 MW gas turbine with SCR. Actual capital costs for CUSA were in the range of $5 million to $6 million per unit, with significant percentage of the costs being attributable to facility redesign work and infrastructure upgrade to accommodate the SCR. This did not take into consideration the significant revenue lost when the equipment is taken off-line to install the controls. The District s cost effectiveness analysis does not take into consideration the cost to modify existing structures in order to retrofit the engines with SCR systems and larger nonselective converters. (WSPA, CUSA, EMA, WKWD) RESPONSE: District staff reviewed the submitted cost analysis. In order to mitigate the high cost effectiveness values for certain engine control retrofit costs, the draft rule includes a provision for payment of annual fees in lieu of complying with the proposed NOx emission limit. The District will use the money collected from the annual fee payments to fund air quality projects that are less expensive but still achieve an equivalent or greater reductions that would have been achieved had the engines been retrofitted with controls to meet the rule emission limits. It is important to note that many of the existing permitted engines within the Valley are already meeting the proposed emission limits with their current emission control system. The District s rule development process for this rulemaking project provides stakeholders and interested parties an ample opportunity to provide their compliance cost estimate so District staff can refine the cost effectiveness analysis. Staff would like to thank those stakeholders who have provided new cost information and helped refine the District s analysis. Appendix C of the Draft Staff Report uses the best cost data that are available to District staff at this time and has been amended to include an allowance for facility modification. Staff continues to encourage stakeholders to provide cost data to the District in order to improve the cost effectiveness analysis and socioeconomic impact analysis. 29. COMMENT: The SJVAPCD should consider lean-burn engines at public water districts as a separate category and maintain the standards at the current level to allow local these agencies time needed to examine their alternatives for future attainment as well as obtaining funding necessary to achieve these goals. (BVCSD, SSCSD, TCCWD, WKWD) RESPONSE: Although the rule is stringent, it allows for compliance options such as the limited use provision, staged compliance, and the annual fee. Additionally, the draft rule contains a compliance schedule to allow time for the design and budgeting of any necessary controls. Temporary payment of the A - 13

14 annual fee would allow water districts additional time to consider their best attainment strategy while still allowing reductions in air pollution to occur. 30. COMMENT: When compiling data for socioeconomic analysis, the District should incorporate a percentage cost per stakeholder for the rule going through an amendment changes. The District should also include listing the previous amended rules that are still in process within the last three years by which stakeholders are still being financially affected. The District should give additional serious consideration to the methodology of the 10% insignificant impact equation that has potential multiple impacts on stakeholders, not only from the District, but through many other regulatory bodies such as state, federal, city, and county with whom the stakeholders deal. (RWRF) RESPONSE: California Health and Safety Code Section (a) mandates analyzing the economic impacts of the rule amendments being considered, but not the cumulative impacts of other rules that have already been adopted or implemented. Further, the requirements imposed by other regulating agencies are independent of District control. Assessing how regulations other than the rule project itself would affect stakeholders would be purely speculative on the part of District staff, especially in the light of general stakeholder reluctance to publicly release information that is considered business-sensitive. District staff encourages stakeholders to submit estimated costs as well as information on how they will fund the added compliance cost in order to help District staff accurately assess impacts to stakeholders. 31. COMMENT: Rule 4702 is not addressing the major cause of ozone in the Valley. The proposed rule is not cost effective; it is very expensive for marginal improvements in air quality. (ACWA, GHCSD) RESPONSE: Computer modeling suggests that most of the pollution in the Valley is from mobile sources. The District has no authority to set limits on mobile sources; however, the federal Clean Air Act requires that non-attainment areas like the District reduce emissions on the sources it can control, without regard to whether stationary sources are the main source of the overall pollution. For this reason, the District is committed to working with stakeholders to set the lowest possible limits in order to meet the provisions of the federal Clean Air Act. A - 14