3.3 Fuel Combustion - Turbines & Engines
| Category ID | Description | EIC |
|---|---|---|
| 302 | Reciprocating Engines - Gasoline | Various |
| 303 | Reciprocating Engines - Gas Fuel | Various |
| 304 | Reciprocating Engines - Liquid Fuel | Various |
| 305 | Turbines - Gas Fuel | 6004500120000 |
| 306 | Turbines - Liquid Fuel | Various |
| 1578 | Reciprocating Engines - Liquid Fuel | 5204010000000 |
Introduction
Greenhouse gas (GHG) emissions from fuel combustion in turbines and reciprocating engines in the San Francisco Bay Area (SFBA) depend primarily on the type of fuel used and the specific characteristics of the combustion equipment. Key factors influencing emissions include fuel composition, combustion efficiency, and engine design. These combustion sources are found in a variety of settings, including industrial, utility, and refinery facilities.
The primary GHG emitted from these combustion processes is carbon dioxide (CO₂), which results directly from the oxidation of fossil fuels. Smaller quantities of methane (CH₄) and nitrous oxide (N₂O) are also released. Although emitted in lower volumes, CH₄ and N₂O have significantly higher global warming potentials (GWPs) than CO₂, making them important to account for in emissions inventories.
To facilitate emissions tracking and analysis, these sources are categorized by equipment type and fuel used:
- Category 302 – Gasoline-Fired Reciprocating Engines: Includes equipment such as firewater pumps and backup generators, primarily located at refinery sites.
- Category 303 – Gas-Fueled Reciprocating Engines: Covers internal combustion engines powered by gaseous fuels, commonly used by industrial facilities and utility districts.
- Category 304 – Liquid-Fueled Reciprocating Engines: Includes mostly diesel-fueled emergency and standby generators operating across a variety of sectors.
- Category 305 – Gas-Fired Turbines: Captures emissions from stationary gas turbines, including those used for electricity generation or mechanical drive.
- Category 306 – Liquid-Fueled Turbines: Accounts for less common oil-fired turbine combustion sources.
- Category 1578 – Agricultural Pumps (Liquid Fuel): An area source category that includes diesel-fueled irrigation pumps used in agricultural operations.
Methodology
Permitted Sources (Categories 302 - 306)
Point sources are operations that emit air pollution into the atmosphere at a fixed location within a facility, and for which the Bay Area Air Quality Management District (BAAQMD or the Air District) has issued a permit to operate (PTO), e.g. refinery cooling towers. These point sources could also be a collection of similar equipment and/or sources located across multiple facilities, e.g. reciprocating engines.
During the PTO issuance process, the Air District collects site-specific information from the operating facility and/or determines from published literature, e.g. United States Environmental Protection Agency’s (USEPA) AP-42 (USEPA, 2024), characteristics of a source including maximum throughput, emission factors for emitted pollutants, and control factors associated with downstream abatement devices. This data is then compared against the Air District’s Regulations to ensure compliance. Facilities that hold a PTO are required to renew their permit periodically (this period varies based on facility and source type). Upon renewal, the facilities are requested to provide any updates to source characteristics as well as the source throughput for the past twelve months. This throughput, in combination with the emission factors and controls factors stored in the Air District’s internal database, are used to programmatically estimate annual emissions at the source level. The methodology used to calculate emissions for the reported base year(s) of a permitted point source is as follows:
Base Year(s) Emissions source,pollutant =
Activity Data source × Emission Factorpollutant × Control Factorpollutant × GWP pollutant
Base Year(s) Emissions county = ∑ Ni=1 Emissionsi
Where:
- Base Year: is a year for which activity / throughput data is available from permit records.
- Activity Data source is the throughput or activity data for applicable base year(s) at the source/equipment level. This data is usually available from the internal permit records that are provided annually to the Air District at permit renewal by the facility operator.
- Emission Factorpollutant is a factor that allocates an amount of emissions, in mass, of a particular pollutant by unit of activity data. For example, tons CO2 per gallons of gasoline burned or pounds of N2O per million standard cubic feet of natural gas combusted. GHG emissions are calculated by using specific emission factors for every source/operation for which information has been supplied by the facility (and verified/validated through source tests). If no specific emission factors are available, generalized factors developed by Air District staff are used to determine emissions. These default factors typically come from published literature such as USEPA’s AP-42 (USEPA, 2024) or California Air Resource Board’s (CARB) Mandatory Reporting Requirement (CARB, 2019) for Greenhouse Gases.
- Control Factorpollutant is a fractional ratio (between 0 and 1) that captures the estimated reduction in emissions as a result of District rules and regulations.
- GWP pollutant is the Global Warming Potential. The current version of the GHG emissions inventory incorporates the global warming potential (GWP) reported in the Fifth Assessment report of the Intergovernmental Panel for Climate Change (IPCC, 2014). The GWPs for the three principal GHGs are 1 for carbon dioxide (CO2), 34 for methane (CH4), and 298 for nitrous oxide (N2O), when calculated on a 100-year basis with climate-carbon feedback included.
- N is the number of permitted and similar sources in a county.
If available, a facility can provide emission factors specific to the source that are verified and validated through source tests to estimate GHG emissions. If no specific emission factors are available, general factors developed by Air District staff are used to estimate emissions. These source level emissions are then sorted and aggregated by year, county, and category.
Further speciation and quality assurance of emissions, including those of GHGs, are performed as a part of the inventory refinement process. A systematic crosswalk has been developed between CARB’s California Emissions Projection Analysis Model (CEPAM) source category classification using the primary sector emission inventory codes (EICs) and the Air District’s source category classification (category identification number - cat_ids), which ensures consistency when reporting annual emissions under the California Emissions Inventory Data Analysis and Reporting Systems (CEIDARS) to CARB (CARB, 2022a). This emissions data represents the reported base years emissions for a point source category.
Once base year emissions are determined, historical backcasting and forecasting of emissions relative to the base year emissions are estimated using growth profiles as follows:
Current Year Emissionscounty = Base Year(s) Emissioncounty x Growth Factor
Where:
- Growth Factor: is a scaling factor that is used to derive historical emissions estimates for years for which activity data and/or emissions are not available, and to forecast emissions for future years, using surrogates that are assumed to be representative of activity and/or emissions trends.
For those years where no data is available, emissions data are backcast to the year 1990, as well as forecasted to year 2050 using either interpolation or another mathematical approach (see Trends section), or by applying a growth profile based on socioeconomic indicators. GHG emissions data from the years 1990 to 2050, including the projections outlined below, are analyzed for each source category and pollutant, with the trends evaluated for any observed anomalies and modified, if needed:
- Historical Backcast (1990 – 2006): Association of Bay Area Governments (ABAG) Employment growth profiles (ABAG, 2024) and scaled District permitted data
- Base Years (2007 – 2022): District permitted data
- Future Projection (2023 – 2050)
- The fuel use forecast for fuel combustion sources in category 303 and 305 is based on the California Energy Commission's (CEC) 2023 Integrated Energy Policy Report (CEC, 2023).
- The forecast for fuel combustion sources involving other fuels (categories 302, 304, and 306) is based on energy demand projections by fuel type, derived from CARB’s E3 Pathways model as outlined in the 2022 Scoping Plan (CARB, 2022b).
Emissions data is finally aggregated under sub-sectors and sectors for tracking trends and documentation purposes.
Local Controls
While several local regulations target emissions from stationary combustion equipment in the Bay Area, they primarily address criteria pollutants such as nitrogen oxides (NOx) and carbon monoxide (CO), rather than GHGs. However, these controls may have indirect impacts on GHG emissions by encouraging more efficient combustion or fuel switching.
Regulation 9, Rule 8 (BAAQMD, 2007) applies to stationary internal combustion (IC) engines rated at 250 brake horsepower (bhp) or greater and fueled by gaseous fuels such as natural gas or liquefied petroleum gas (LPG). This rule affects permitted reciprocating engines included in Categories 302, 303, and 304. The 2007 amendments to Rule 9-8 aimed to reduce particulate matter and ozone precursors by tightening NOx emission limits, but they do not impose any direct requirements on GHG emissions. Any indirect GHG reductions associated with improved combustion efficiency are already captured in operator-reported data used in this inventory.
Regulation 9, Rule 9 (BAAQMD, 2006) regulates NOx emissions from stationary gas turbines, applicable to sources in Category 305. The 2006 amendments refined emission limits and shifted regulatory focus from power output to heat input for more consistent enforcement across turbine types. Like Rule 9-8, Rule 9-9 does not directly target GHGs. Any impact on GHG emissions due to increased operational efficiency or technology upgrades is already reflected in the emissions estimation methodology.
In summary, while local air quality regulations may influence combustion efficiency or technology selection, they do not impose direct limits on CO₂, CH₄, or N₂O emissions. Therefore, no additional GHG emission reductions are attributed to these control rules in this analysis.
Historical Emissions
Historical emissions for point sources are derived from source-specific data provided by the facility on throughputs, compiled or reported emission factors, and regulation-based control factors. This information is archived in the Air District’s internal database and is queried to retrieve the data for historical and current years. Interpolation techniques to account for missing data are used when necessary.
In the case of GHGs, up until the year 2006, the Air District was not engaged in systematic information collection during permit renewal process. This changed when AB32 bill was passed into a statewide law in 2006, and a statewide Cap and Trade system was introduced to reduce GHG emissions from specific facilities. Hence, GHG emissions data for years 1990-2006 are derived from the historical emissions data reported in the base year 2011 GHG inventory (released in year 2012). The historic emissions dataset is scaled to sync with the data in the permit database (which started systematic GHG data accounting from year 2006 onwards), to generate a complete GHG emissions time series for each point source category from 1990 to 2050.
Future Projections
Forecasting of point source emissions is done based on calculations as shown in the equation below using recently updated growth profiles and a base year of 2022. The growth profiles for the current base year inventory have been verified and updated to represent the most likely surrogate for forecasting emissions for a given category up to the year 2050. Forecasting for point source emissions includes impact of in-place regulations but does not include estimation of controls that will theoretically be implemented as part of future policy emission targets or proposed regulation and legislation.
PE = Gr × Ci × Ei
PE = projected emissions of pollutant i in a future year
Gr = growth rate by economic profile of industry or population
Ci = control factor of pollutant i based on adopted rules and regulations
Ei = base year emissions of pollutant i
The fuel use forecast for fuel combustion sources in category 303 and 305 is based on the California Energy Commission's (CEC) 2023 Integrated Energy Policy Report (CEC, 2023). This report provides updated projections on energy demand and fuel consumption trends for natural gas, offering valuable insights into future energy needs for these sources.
Forecast for industrial sector energy use associated with fuel combustion sources involving different fuels (categories 302, 304, and 306) are applied from CARB’s E3 Pathways model as used in their 2022 Scoping Plan (CARB, 2022b). The E3 forecasting model predicts energy consumption trends in the Industrial sector, factoring in the shift toward zero-emission technologies. This demand is forecasted to decrease as zero-emissions technologies are promoted and adopted. The forecast also accounts for historical emissions, which show an overall downward trend at the state level for the industrial sector.
Area Sources (Category 1578)
Category 1578 is classified as an area source category, since it represents emissions from agricultural irrigation pumps that are not directly permitted by the Air District and are therefore not routinely or annually reported. Emission estimates for this source rely on data from CARB CEPAM2019 (v1.03) Standard Emission Tool (CARB, 2024).
The general methodology used by CARB to calculate emissions for the reported base year(s) for these categories is as follows:
Base Year Emissionscounty,pollutant =
Emissionsstate;national,pollutant × Control Factorpollutant × Fractioncounty × Fractionin District × GWPpollutant
Where:
- Base Years: are years for which activity / throughput data are available in order to calculate emissions.
- Emissionsstate;national,pollutant: is the amount of emissions from a larger area (e.g., state or national level) to be allocated to a smaller regional area based on a proportional measure, such as the ratio of county to state population.
- Emission Factorpollutant: is a factor that allocates a mass amount of emissions of a particular pollutant per unit of activity.
- Control Factorpollutant: is a fractional ratio (between 0 and 1) that estimates reductions in emissions from adopted rules and regulations.
- Fractioncounty: is the fraction of total regional emissions (between 0 and 1) estimated to be allocated to a particular county.
- Fractionin District: The Air District jurisdiction covers only a portion of Solano and Sonoma County and, therefore, an additional allocation is applied to these counties that proportions each county’s emissions that are within Air District’s boundary.
- GWPpollutant: is the Global Warming Potential of a particular GHG pollutant. The current version of the GHG emissions inventory incorporates the global warming potential (GWP) reported in the Fifth Assessment report of the Intergovernmental Panel for Climate Change (IPCC, 2014). The GWPs for the three principal GHGs are 1 for carbon dioxide (CO2), 34 for methane (CH4), and 298 for nitrous oxide (N2O), when calculated on a 100-year basis with climate-carbon feedback included.
This approach allows derivation of emissions data for the years 2000-2050. Once base year emissions are determined, historical backcasting and forecasting of emissions relative to the base year emissions are estimated using growth profiles as follows:
Current Year Emissionscounty = Base Year(s) Emissioncounty x Growth Factor
Where:
- Growth Factor: is a scaling factor that is used to derive historical emissions estimates for years for which activity data and/or emissions are not available, and to forecast emissions for future years, using surrogates that are assumed to be representative of activity and/or emissions trends.
More details on the county distribution of emissions, emission factors and controls are provided in the following subsections:
Emissions Apportionment
While CEPAM2019 offers detailed emissions data for criteria pollutants, it does not provide estimates for GHGs such as CO2, CH4, and N2O. To account for greenhouse gases, the emissions of CO2, CH₄, and N₂O are estimated by leveraging the criteria pollutant emissions data provided by the CARB CEPAM2019 tool. This approach utilizes the existing emissions data for criteria pollutants, such as carbon monoxide (CO), total organic gases (TOG), and reactive organic gases (ROG), as a basis for predicting the relative levels of these greenhouse gases:
- CO2: Applying ratios of CO2 and CO emission factors (EPA AP-42, Vol. 1, Table 3.3-1; USEPA, 1998) to CEPAM2019 CO emissions
- CH4: Subtracting CEPAM2019 reactive organic gases (ROG) from total organic gases (TOG)
- N2O: Applying ratios of N2O and CO emission factors (Code of Federal Regulations, Table C-2 Subpart C; USEPA, 2016) to CEPAM2019 CO emissions
This method utilizes constant ratios to estimate the emissions of all major GHG pollutants. These ratios are applied in conjunction with CO, TOG and ROG emission trends provided by the CARB CEPAM2019 Standard Emission Tool. Specifically, the CO emission trends, which reflect changes in emissions over time, serve as a basis for predicting the relative emissions levels of CO2 and N₂O. By using this approach, the method provides consistent and comparable estimates for all relevant GHGs, ensuring that emissions from agricultural irrigation pumps are accounted for in a consistent manner.
CEPAM2019 provides detailed estimates of criteria air pollutant emissions—such as carbon monoxide (CO), total organic gases (TOG), and reactive organic gases (ROG) but does not directly include GHG emissions for off-road mobile equipment, including agricultural irrigation pumps. To develop a comprehensive emissions inventory, GHG emissions for this category are estimated using a surrogate-based method that leverages the criteria pollutant data from CEPAM2019.
This approach involves the following steps:
1. Estimating CO₂ Emissions from CO Emissions
CO₂ emissions are calculated using a ratio of emission factors for CO₂ and CO obtained from U.S. EPA AP-42, Volume 1, Table 3.3-1 (USEPA, 1998). These emission factors represent average emissions per unit of energy output for small, uncontrolled internal combustion engines.
Equation:
CO₂ = COCEPAM × (EFCO₂ / EFCO)
Where:
- CO₂ = estimated CO₂ emissions (tons/year)
- COCEPAM = CO emissions from CEPAM2019 (tons/year)
- EFCO₂ = CO₂ emission factor (g/hp-hr)
- EFCO = CO emission factor (g/hp-hr)
2. Estimating CH₄ Emissions Using TOG and ROG
Methane is considered a non-reactive component of total organic gases. To estimate CH₄, the reactive portion (ROG) is subtracted from total organic gas emissions (TOG):
Equation:
CH₄ = TOGCEPAM − ROGCEPAM
Where:
- CH₄ = estimated CH₄ emissions (tons/year)
- TOGCEPAM = total organic gas emissions from CEPAM2019 (tons/year)
- ROGCEPAM = reactive organic gas emissions from CEPAM2019 (tons/year)
3. Estimating N₂O Emissions from CO Emissions
Similar to the method used for estimating CO2 emissions, N₂O emissions are estimated using a ratio of N₂O and CO emission factors based on data from the U.S. EPA’s Greenhouse Gas Reporting Program (40 CFR Part 98, Table C-2, Subpart C; USEPA, 2016).
Equation:
N₂O = COCEPAM × (EFN₂O / EFCO)
Where:
- N₂O = estimated N₂O emissions (tons)
- COCEPAM = CO emissions from CEPAM2019 (tons)
- EFN₂O = N₂O emission factor (g/hp-hr)
- EFCO = CO emission factor (g/hp-hr)
County Distribution
County-level emissions are sourced directly from CEPAM2019 for counties in the SFBA. For Solano and Sonoma, CEPAM2019 automatically subsets emissions for the portion of the counties within the SFBA, so no additional adjustment is necessary.
Local Controls
Agricultural irrigation pumps are primarily regulated by CARB and are not subject to additional local regulations from the Air District. While these pumps are relatively minor sources of greenhouse gases in the Bay Area, they are recognized statewide as contributors to both criteria pollutant and GHG emissions, particularly in regions with intensive agricultural activity.
To reduce emissions from this sector, CARB administers the Carl Moyer Program, a grant program established in 1998 to incentivize voluntary upgrades or replacements of older, high-emitting engines and equipment. This program provides financial support for the purchase of cleaner technologies, including new stationary or portable engines used for agricultural irrigation.
Under the 2017 Carl Moyer Program Guidelines (CARB, 2017), funding is available for a range of eligible agricultural projects, including:
- Replacement of older diesel- or gasoline-powered engines with cleaner models;
- Retrofitting engines with emission control technologies;
- Non-engine upgrades that result in measurable emission reductions.
| ID | Description | ALA | CC | MAR | NAP | SF | SM | SNC | SOL | SON |
|---|---|---|---|---|---|---|---|---|---|---|
| 1578 | Reciprocating Engines - Liquid Fuel | 0.07 | 0.22 | 0.01 | 0.21 | 0.00 | 0.04 | 0.19 | 0.14 | 0.13 |
| 303 | Reciprocating Engines - Gas Fuel | 0.01 | 0.23 | 0.01 | 0.04 | 0.01 | 0.59 | 0.04 | 0.06 | 0.01 |
| 304 | Reciprocating Engines - Liquid Fuel | 0.12 | 0.08 | 0.04 | 0.16 | 0.08 | 0.10 | 0.31 | 0.04 | 0.07 |
| 305 | Turbines - Gas Fuel | 0.00 | 0.00 | 0.00 | 0.00 | 0.00 | 0.00 | 0.00 | 1.00 | 0.00 |
| 306 | Turbines - Liquid Fuel | 0.03 | 0.00 | 0.00 | 0.00 | 0.96 | 0.01 | 0.00 | 0.00 | 0.00 |
Historical Emissions
Historical emissions data from 1990 to 1999 were originally derived from CARB CEPAM SIP2016, which was a previous version of the CARB CEPAM tool. For 2000 to 2021, historical emissions are obtained from CARB CEPAM2019.
Future Projections
Projections for emissions from agricultural irrigation pump sources for 2023 to 2050 are obtained from CARB CEPAM2019.
Sample Calculations
The table below illustrates a sample calculation for estimating emissions from fuel combustion in agricultural pumps (Category 1578) in Napa County for the base year 2022 in units of metric tons of CO2 equivalents (MTCO2eq).
TOG | ROG | CO | ||
Step 1 | Obtain 2022 criteria air pollutant emissions for Napa County from CARB CEPAM2019 | 0.0018 | 0.00105 | 0.0157 |
CO2 | N2O | CO | ||
Step 2 | Obtain emission factors from EPA AP-42 | 164 | 0.0013 | 0.95 |
Step 3 | Calculate CO2 and N2O emission factor ratios relative to CO | 164 / 0.95 = 171.64 | 0.0013 / 0.95 = 0.0014 | |
CO2 | CH4 | N2O | ||
Step 4 | IPCC AR5 GWP | 1 | 34 | 298 |
Step 5 | Calculate 2022 emissions for Napa County | 0.0157 tons/day × 171.64 × 365 days/year × 0.9072 MT/ton × 1 = 892 MTCO2eq | (0.0018 - 0.00105) tons/day × 365 days/year × 0.9072 MT/ton × 34 = 8.4 MTCO2eq | 0.0157 tons/day × 0.0014 × 365 days/year × 0.9072 MT/ton × 298 = 2.2 MTCO2eq/yr |
Assessment of Methodology
The methodology for estimating emissions from agricultural pump sources has remained consistent over time, as it primarily relies on the emissions inventory data retrieved from CARB CEPAM.
Base Year | Revision | Reference |
2022 |
|
|
2015 |
|
|
Emissions
The table below shows the total greenhouse gas emissions by pollutant in MTCO2eq for non-refinery fuel combustion turbines and reciprocating engines.
| ID | Description | CFC-11 | CH2Cl2 | CH4 | CO2 | CO2_bio | N2O | Total |
|---|---|---|---|---|---|---|---|---|
| 305 | Turbines - Gas Fuel | 0.0 | 0.0 | 476.0 | 268171.3 | 0.0 | 894.0 | 269541.3 |
| 303 | Reciprocating Engines - Gas Fuel | 23.4 | 0.6 | 16130.7 | 25124.2 | 112379.7 | 109.4 | 153768.0 |
| 304 | Reciprocating Engines - Liquid Fuel | 0.0 | 0.0 | 69.2 | 51427.8 | 12.0 | 132.0 | 51641.0 |
| 1578 | Reciprocating Engines - Liquid Fuel | 0.0 | 0.0 | 40.0 | 4348.4 | 0.0 | 10.6 | 4399.0 |
| 306 | Turbines - Liquid Fuel | 0.0 | 0.0 | 2.7 | 3009.6 | 0.0 | 7.8 | 3020.1 |
Summary of Base Year 2022 Emissions
The table below presents a detailed analysis of the relative contribution of GHG emissions fuel combustion in SFBA turbines and engines to overall regional emissions. Among these sources, fuel combustion in turbines powered by gas fuel (permitted source category 305), which is mostly natural gas, is the primary contributor to GHG emissions in the Industrial sector.
Contribution of Fuel Combustion - Turbines & Engines Emissions by Sector| Subsector | Sector | Subsector GHG Emissions (MMTCO2eq) | Sector GHG Emissions (MMTCO2eq) | % of Sector |
|---|---|---|---|---|
| Fuel Combustion - Turbines & Engines | Industrial | 0.37 | 17.90 | 2.07% |
Contribution of Fuel Combustion - Turbines & Engines Emissions to Regional Total
| Subsector | Subsector GHG Emissions (MMTCO2eq) | Regional Total GHG Emissions (MMTCO2eq) | % of Regional Total |
|---|---|---|---|
| Fuel Combustion - Turbines & Engines | 0.37 | 65.68 | 0.56% |
Trends
The time series chart below shows the emission trends for all categories in this subsector.
Summary of Trends
GHG) emissions from Category 305—which includes gas-fueled turbines and represents the majority of emissions in this subsector—are projected to remain stable over time. This trend is largely due to existing regulatory controls established by the Air District under Regulation 9, Rule 9, which limits emissions from gas turbine operations and has effectively curbed further emission growth in this category.
Uncertainties
As noted above, point source emissions are calculated at an individual source level. The accuracy of these calculations is limited by the accuracy of the specific emission factors applied and estimated throughput. As these emissions are aggregated to create category level summaries, it is difficult to define a quantitative error associated with the total.
For fuel combustion emissions from turbines and engines, there is an additional state level requirement to report greenhouse gases under the CARB Mandatory Reporting Requirement (MRR) (CARB, 2019). These reported emissions are independently validated by a third-party verifier and are generally considered to be the best estimate of greenhouse gas emissions. The Air District’s calculated refinery emissions are compared against these reported and verified emissions to identify any significant outliers. If an outlier is identified, a detailed analysis is done to confirm whether the Air District estimates should be left “as-is” or corrected to align with reported emissions. This additional verification provides more certainty in the emissions presented for the base year.
CARB recently released version 1.04 of the CEPAM2019 tool for criteria pollutant emissions. After evaluation, the Air District determined that the updated agricultural pump data in CEPAM2019 (v1.04) shows no significant change in emissions compared to version 1.03.
Contact
Author: Michael Nguyen
Reviewer: Abhinav Guha
Last Update: 08/27/2025
References
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