Transcript Implementation of SB 700 (Florez)

Implementation of
SB 700 (Florez)
Seyed Sadredin
Director of Permit Services
San Joaquin Valley APCD
November 4, 2003
SB 700 Summary
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Removes permit exemption for
Agricultural sources
Requires controls for PM and PM
precursors
Requires pollution control and permits
for Confined Animal Facilities
Offers off-ramps from pollution control
and permitting
SB 700 – PM Controls
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BACM for sources subject to BACM
BARCT for sources where technology is
applicable
Includes tilling, discing, cultivation, and
raising of animals
Include fugitive emissions
Include measures for PM precursors
Enforceable rules and regulations
SB 700 – BACM/BARCT
Requirements (PM)
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Serious nonattainment areas for PM:
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9/1/04 notice and hold workshop
7/1/05 adopt rules
1/1/06 commence rule implementation
Submit for SIP
Socioeconomic and cost effectiveness
analysis from H&S Code apply
SB 700 – BACM/BARCT
Requirements (PM)
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Moderate nonattainment areas for PM:
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By 1/1/07 adopt and implement rules
required of Serious nonattainment areas
Public workshop prior to adoption
Not required if finding is made that
emissions are not significant
Socioeconomic and cost effectiveness
analysis from H&S Code apply
SB 700 – BACM/BARCT
Requirements (PM)
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By 1/1/05 CAPCOA to establish a
clearinghouse of available control
measures
Consult with CARB
SB 700 – Permitting Provisions
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Removes from the State law the permit
exemption for ALL agricultural activities
Defines “agricultural sources”
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I.C. Engines (including portable)
Confined Animal Facilities
Title V Sources
Sources already regulated by districts
Title V Implications
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Federal permits for major sources
Title V permits required (overriding provision)
1/1/05 – Title V applications due
Issue 1/3 per year and finish by 1/1/07
SB 700 does not change Title V applicability –
(Fugitive emissions don’t count except when required by federal
regulations)
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SB 700 does not change timelines
Refer to district Title V regs.
New Source Review (NSR)
Implications
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NSR governs permitting of new sources
Sources subject to federal Title I must get
permits as prescribed under Title I
Existing sources are grandfathered (i.e., No
BACT & Offsets)
No offsets required for sources not qualifying
to receive Emission Reduction Credits
“Agricultural sources” as
defined by SB 700
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Sources with actual emission at or above
½ of the major source thresholds require
permits (No rulemaking required)
Sources with actual emission below ½ of
the major source thresholds CANNOT be
permitted unless these findings are made:
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Not a large CAF subject to permits
Permits necessary to enforce reductions
Permits not significantly more burdensome
Fugitive emissions
Additional Requirements for
CAFs
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7/1/05 CARB to define Large CAFs
7/1/06 Adopt permitting and mitigation rules
for “Large CAFs”
1/1/07 “CAF permit” applications due –
district issue permits within 6 months – 30day public notice
Sources to implement mitigation within 1 year
Districts review/update permits within 3 years
Additional Requirements for
CAFs (cont’d.)
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Degree of control – RACT (serious and
moderate nonattainment) and BARCT
(severe and extreme)
Attainment areas for Ozone can be
exempted with the following finding:
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Large CAFs do not cause/contribute to a
violation of AAQS
Attainment areas may not submit for SIP
Non-Attainment areas must submit for SIP
Permitting Off-ramps
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Permits not required
Sources with de minimis (1 t/yr) PM10,
NOx, or VOC emissions
Sources that:
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Replace I.C. engines with electrical or
State/EPA certified
Mitigate emissions from all ag activities
Mitigate emissions from all ag equipment
Require rulemaking – NOT mandatory
Available to “Large CAFs”
Permitting Off-ramps
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Sources that:
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(cont’d.)
Are large CAFs subject to permitting
Permit not necessary for reductions
Permit burdensome
Requires public hearing – NOT
mandatory
Permitting Timeline
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Ag. exemption goes away 1/1/2004
SB 700 does not provide additional time
to submit applications
SJVACP rules allow 6 months to apply
for permits
Synchronize Title V and regular
permitting timelines
Public Involvement
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Public Workshops
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Outreach to affected sources
Solicit public/stakeholders suggestions on
implementation strategies
Solicit input and comments on proposed
regulations
Public Hearings
Business assistance to affected facilities