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Implementation of SB 700 _Florez_

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					Implementation of
SB 700 (Florez)

          Seyed Sadredin
    Director of Permit Services
     San Joaquin Valley APCD
        November 4, 2003
SB 700 Summary
   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
   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)
   Serious nonattainment areas for PM:
       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)
   Moderate nonattainment areas for PM:
       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)
   By 1/1/05 CAPCOA to establish a
    clearinghouse of available control
    measures
   Consult with CARB
SB 700 – Permitting Provisions
   Removes from the State law the permit
    exemption for ALL agricultural activities
   Defines “agricultural sources”
       I.C. Engines (including portable)
       Confined Animal Facilities
       Title V Sources
       Sources already regulated by districts
Title V Implications
   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)
   SB 700 does not change timelines
   Refer to district Title V regs.
New Source Review (NSR)
Implications
   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
   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:
       Not a large CAF subject to permits
       Permits necessary to enforce reductions
       Permits not significantly more burdensome
   Fugitive emissions
Additional Requirements for
CAFs
   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 – 30-
    day public notice
   Sources to implement mitigation within 1 year
   Districts review/update permits within 3 years
Additional Requirements for
CAFs (cont’d.)
   Degree of control – RACT (serious and
    moderate nonattainment) and BARCT
    (severe and extreme)
   Attainment areas for Ozone can be
    exempted with the following finding:
       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
   Permits not required
   Sources with de minimis (1 t/yr) PM10,
    NOx, or VOC emissions
   Sources that:
       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               (cont’d.)




   Sources that:
       Are large CAFs subject to permitting
       Permit not necessary for reductions
       Permit burdensome
   Requires public hearing – NOT
    mandatory
Permitting Timeline
   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
   Public Workshops
       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

				
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