Reasonably Available Control Measures (RACM) Process
Moderate Area Ozone SIP

RACM Overview

Under the Clean Air Act, all areas designated Moderate nonattainment for the 2015 8-hour ozone standard are required to implement RACM for point, area, off-road, and on-road source categories. RACM applies only to those point sources not already addressed as part of a RACT analysis. RACM implementation is required to be as expeditiously as practicable. The purpose of the RACM analysis is to determine whether RACM exist that would advance the attainment date for nonattainment areas. Control measures that have been implemented at the federal level, in other states, and in other local air districts must be considered. The general approach to RACM includes the following steps:

  1. Identification of potential control measures that are reasonable
  2. Modeling to identify the attainment date that is as expeditious as practicable
  3. Selection of RACM

A RACM analysis determines potential control measures for each source category considering the following requirements:

  • Technological feasibility of the control measure
  • Economic feasibility of the control measure
  • If the control measure would cause substantial widespread and long-term adverse impacts
  • If the control measure is absurd, unenforceable, or impracticable
  • If the control measure can advance the attainment date by at least one year

An ozone Moderate nonattainment RACM analysis would examine control measures for all potential VOC and NOx emission sources. For areas in the Wasatch Front nonattainment area, the DAQ underwent a BACM analysis for VOC and NOx emissions for the Serious PM2.5 SIP development. The DAQ may consider these existing measures for an ozone Moderate nonattainment RACM analysis.

Source Categories

As part of a RACM analysis, consideration will be given to a broad list of source categories. The DAQ will implement control strategies that apply to area source categories through air quality rules that will apply to every source within a particular area source category. The DAQ will update this list as ozone Moderate nonattainment SIP development progresses.

DAQ already has area source rules for areas in the Wasatch Front for the Serious PM2.5 SIP. As part of the ozone Moderate nonattainment SIP, DAQ will re-evaluate these rules to determine if they meet RACM for ozone, as well as determine additional area source categories where new area source rules would be appropriate for RACM.

Current Area Source Rules for areas in the Wasatch Front that may be applicable:

RACM Analysis for Northern Wasatch Front NAA

Below is the current RACM analysis performed for the Northern Wasatch Front (NWF) moderate ozone NAA for eventual inclusion into the moderate SIP. This analysis provides a review of control measures that have already been implemented as part of the Salt Lake PM2.5 Serious State Implementation Plan (SIP). Those measures have been deemed by UDAQ to be best available control measures (BACM) and have also been approved by EPA. BACM are more stringent than RACM thus, as anticipated, the RACM analysis concluded that current control measures are sufficient to meet the requirements for the moderate ozone SIP. Further, this analysis evaluated whether additional control measures are available that were not included in the Salt Lake PM2.5 Serious SIP that could be helpful in advancing attainment of the ozone standard. No further rules were identified as being needed to meet ozone RACM requirements. If you have comments or suggestions after reviewing this draft analysis, please direct them to UDAQ staff: (801) 536-4000.

UDAQ Ozone RACT/RACM Email Alerts

Join the DAQ ozone RACT/RACM email list and stay up to date with all information pertaining to Utah’s ozone RACT/RACM process. Relevant information for affected sources, operators, and consultants will be periodically emailed out. Sign up for email alerts here: