The SCAQMD NOx RECLAIM program is over. After more than 30 years of market-based emissions trading, the program officially sunset in January 2026. For the hundreds of facilities that operated under RECLAIM, the regulatory landscape has fundamentally shifted.
No more RECLAIM Trading Credits. No more buying your way out of equipment-level compliance. Every permitted unit at your facility must now meet individual emission limits under command-and-control rules.
If you have not started your transition work, you are behind. Here is what changed and what you need to do about it.
What RECLAIM Was
RECLAIM (Regional Clean Air Incentives Market) launched in 1994 as a cap-and-trade program for NOx and SOx emissions in the South Coast Air Basin. Instead of equipment-level limits, each facility received an annual allocation of RECLAIM Trading Credits (RTCs). Emit below your allocation, sell surplus credits. Exceed it, buy from the market.
It worked for a time. Basin-wide NOx dropped. But RTC prices became volatile, some facilities banked credits without actually reducing emissions, and RECLAIM participants were exempt from BARCT requirements. As the Basin continued missing federal ozone attainment deadlines, SCAQMD concluded the program was no longer delivering sufficient reductions.
The SOx component ended earlier. The NOx component sunset in January 2026.
What Changed on January 1, 2026
The transition is not a minor rule adjustment. It restructures how former RECLAIM facilities are regulated.
No More Trading Credits
RTCs are no longer valid. You cannot buy, sell, or bank credits. Each facility must demonstrate compliance with emission limits on a unit-by-unit basis. Excess emissions from one unit cannot be offset by lower emissions from another unit, even within the same facility.
This is the single biggest operational change. Under RECLAIM, a facility with ten boilers could have one or two running hot as long as the facility total stayed under its allocation. That flexibility is gone.
Landing Rules Apply
Former RECLAIM facilities must now comply with equipment-specific "landing rules." These are the SCAQMD rules that would have applied to the equipment if it had never been in RECLAIM. The primary landing rules are:
- Rule 1135: Emissions of Oxides of Nitrogen from Electricity Generating Facilities. Covers power plants, cogeneration units, and other electric generating equipment.
- Rule 1109.1: Emissions of Oxides of Nitrogen from Petroleum Refineries and Related Operations. Covers refinery process heaters, boilers, fluid catalytic cracking units, and other refinery equipment.
- Rule 1134: Emissions of Oxides of Nitrogen from Stationary Gas Turbines. Covers gas turbines used in power generation, pipeline compression, and industrial processes.
Each landing rule specifies BARCT emission limits for the equipment categories it covers. BARCT is not a suggestion. It is the maximum emission rate that SCAQMD has determined is achievable with current technology, taking into account cost-effectiveness.
For many facilities, BARCT limits are significantly tighter than the effective emission rates they operated under with RECLAIM credits. Equipment that was "in compliance" under RECLAIM may not meet BARCT limits without modifications, retrofits, or replacement.
Title V Federal Major Modification Triggers
Any NOx or VOC emission increase at a Title V major source now constitutes a Federal Major Modification under the Clean Air Act's New Source Review program. Under RECLAIM, facility-level tracking provided flexibility. Now, any increase above unit-level permitted limits triggers NSR, requiring BACT determinations, air quality impact analysis, and potentially emission offsets. The process takes months to years and costs hundreds of thousands of dollars.
Tighter CEMS Standards Under Rules 218.2 and 218.3
SCAQMD updated Rules 218.2 and 218.3 in conjunction with the RECLAIM sunset. The key change: the NOx de minimis threshold dropped from 1.0 ppm to 0.5 ppm.
Under the old standard, CEMS reading within 1.0 ppm of the reference method value passed the de minimis test. With the threshold now at 0.5 ppm, your CEMS must be more precise at low concentrations. Facilities running ultra-low NOx burners in the 2 to 5 ppm range are most affected. At those levels, a 0.5 ppm de minimis is a tight window.
If your last RATA was performed under old RECLAIM-era rules, expect additional preparation: analyzer maintenance, calibration verification, and potentially new calibration gas concentrations.
What Your Facility Must Do Now
The transition creates immediate compliance obligations. Here is the work that needs to happen.
1. Identify Your Landing Rules
Determine which landing rule applies to each piece of equipment at your facility. This is not always straightforward. Some facilities have equipment that spans multiple rules. A refinery with both process heaters (Rule 1109.1) and gas turbines (Rule 1134) must comply with both.
Review your permit conditions. If SCAQMD has not already issued amended permits reflecting your landing rule requirements, contact the district to confirm your obligations.
2. Source Test Each Permitted Unit
Facility-wide CEMS data or limited source testing is no longer sufficient. Each permitted unit must be individually source tested against BARCT limits: individual stack testing for NOx, CO, and other applicable pollutants, protocol submission and SCAQMD approval before testing, and final report within 60 calendar days.
For a facility with 10 or 20+ permitted units, this is a significant testing campaign requiring early planning and coordination with your source testing firm.
3. Recertify Your CEMS
If you operate CEMS, recertification under updated Rules 218.2/218.3 is mandatory. Your next RATA must meet the 0.5 ppm NOx de minimis. Verify calibration gases and daily procedures align with new requirements. Ensure your DAHS captures data in the landing rule format, not the old RECLAIM reporting format.
Operating a CEMS that does not meet current rules is itself a violation.
4. Evaluate Equipment for BARCT Compliance
Some equipment will not meet BARCT limits without physical modifications: burner replacements, SCR installation or optimization, combustion tuning, fuel switching, or full equipment replacement. If your equipment cannot meet BARCT, develop a compliance plan. SCAQMD may allow compliance schedules, but they are not open-ended.
5. Update Compliance Systems and Watch for NSR Triggers
Your recordkeeping, monitoring, and reporting must shift from facility-wide RECLAIM totals to unit-level tracking under landing rules. Update emission tracking, CEMS reporting formats, source testing schedules, and train operations staff on new procedures.
Any planned operational change or equipment modification must be screened for NSR applicability before implementation. Under RECLAIM, you had emission trading flexibility. That is gone. What would have been a routine adjustment could now trigger a Federal Major Modification.
The Testing Demand Surge
Hundreds of former RECLAIM facilities need testing on multiple units, many for the first time in years. Testing companies are booking out weeks to months in advance. If you have not contacted a source testing firm, do it now. Every week of delay increases the risk of missing a compliance deadline.
Frequently Asked Questions
The SOx RECLAIM component sunset earlier than the NOx component. If your facility was in both programs, you should already be complying with SOx landing rules. The January 2026 sunset specifically ended the NOx RECLAIM program. Review both your NOx and SOx compliance obligations to ensure you are covered on all fronts.
You must develop a compliance plan. Options include equipment retrofit (burner replacement, SCR installation), operational modifications (fuel switching, load reduction), or equipment replacement. Contact SCAQMD to discuss compliance schedules if you need additional time. However, SCAQMD expects facilities to move toward compliance without unreasonable delay. Operating above BARCT limits without an approved compliance plan is a violation.
The NOx de minimis threshold has tightened under updated Rules 218.2 and 218.3. This means your CEMS must demonstrate greater precision at low NOx concentrations. Facilities running ultra-low NOx equipment will find the tighter standard particularly challenging. Schedule analyzer maintenance, verify calibration gas accuracy, and consider a pre-RATA diagnostic with your testing firm before the formal audit.
No. Under RECLAIM, facilities could balance emissions across units as long as the total stayed within the RTC allocation. Under landing rules, each unit must individually meet its applicable BARCT limit. There is no intra-facility trading or netting. If one unit exceeds its limit, that unit is in violation regardless of how other units perform.
Accurate Environmental Services is a CARB/SCAQMD LAP-approved source testing company based in Stanton, CA. We are actively supporting former RECLAIM facilities through the transition with unit-level source testing, CEMS RATA under the new Rules 218.2/218.3 standards, and protocol preparation.
Call (714) 379-9200, email wallymoe@accuenviro.com, or request a quote at accuenviro.com