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Programmatic New Source Review

Programmatic New Source Review. Malcolm C. Weiss Jeffer, Mangels, Butler & Marmaro LLP 1900 Avenue of the Stars Los Angeles, CA 80067 (310) 712-6822 mweiss@jmbm.com 3748292. November 2, 2005. Responsible Agencies.

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Programmatic New Source Review

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  1. ProgrammaticNew Source Review Malcolm C. Weiss Jeffer, Mangels, Butler & Marmaro LLP 1900 Avenue of the Stars Los Angeles, CA 80067 (310) 712-6822 mweiss@jmbm.com 3748292 November 2, 2005

  2. Responsible Agencies • Federal – U.S. Environmental Protection Agency (implements CAA, sets goals, national policies and regulatory framework) • State – California Air Resources Board (mobile sources, coordinate with local/federal agencies, state standards, SIP) • Local – Air Quality Management Districts (SCAQMD) (stationary sources, permitting, prohibitory rules, compliance, AQMP, MR&R)

  3. Clean Air Laws Overview • 1970 – Fed. Clean Air Act Adopted • 1977 – Major Amendment to CAA • 1988 – California CAA • 1990 – Major New Amendments

  4. 1970 Clean Air Act • First major federal air legislation • U.S. EPA created (ARB created in 1967) • Earth Day - April 22, 1970

  5. 1970 Clean Air Act (cont.) • Authority delegated to states • Establishes National Ambient Air Quality Standards (NAAQS) • State Implementation Plans required • Begins national permit programs • New Source Review (NSR) • States to meet NAAQS by 1975

  6. 1977 CAA Amendments • Gives states more time to meet NAAQS • Expands NSR • Applicable to new sources • Major modifications at existing facilities • Review of NAAQS by 1980 • Attainment and Nonattainment areas

  7. 1977 CAA Amendments(cont.) • Basic Applicable Requirements • Prevention of Significant Deterioration of Air Quality (Part C) (“PSD”) • Plan Requirements for Nonattainment areas (Part D) (“NSR”)

  8. 1990 CAA Amendments Overview • Title I - Attain and maintain NAAQS • Title II - Mobile sources • Title III - Hazardous air pollutants • Title IV - Control acid rain • Title V - National uniform permit system • Title VI - Stratospheric ozone protection • Title VII - Enforcement

  9. 1990 CAA Amendments • Classifies ozone nonattainment areas – marginal, moderate, serious, severe, and extreme • Classifications trigger stringency of requirements • Extends attainment dates for extreme areas

  10. 1970 California's population is 20 million More than 12 million vehicles VMT is 110 billion miles 2000 California's population is 34 million More than 23 million vehicles VMT is 280 billion miles CaliforniaThen and Now

  11. Motor Vehicle Impacts • Up to 50% of NOx and VOC (smog) • > 50% of hazardous air pollutants • 90% CO in urban areas

  12. SCAQMD Air Quality Analysis Overall Planning Stationary Sources SCAG Transportation Growth Management Land Use ARB Mobile sources Vehicle standards/ fuel Consumer products Strategies All known control technologies Technology forcing and incentives Major technology breakthroughs Air Quality Management Plan

  13. Part D of Title I: Federal NSR • Permits required to construct new or modified major stationary sources • NSR and the permitting process are linked • Expanded opportunity for public comments

  14. Federal NSR(cont.) • New Sources - NSR is triggered only if the emissions make it a major source • Existing Sources - NSR is triggered if the modification significantly increases emissions

  15. Federal NSR(cont.) • Permits to Construct/Operate require that major stationary sources: • Install equipment to meet the Lowest Achievable Emission Rate (LAER) • Obtain offsets (ratios) • Demonstrate that all major sources under common ownership/control comply

  16. NSR Reform • Reform was urged because of the growing indication that current regulations hinder, rather than promote improvements in air quality • SCAQMD has filed a lawsuit contesting the reforms

  17. NSR Reform • Routine Equipment Replacement Rule (10/27/03). Equipment replacement is excluded from NSR if: • It replaces an existing process unit; • with functionally equivalent components; • the cost of the replaced is < 20% of the replacement value of the entire process unit; • the basic design of the equipment does not change; and • emissions limits not exceeded.

  18. ProgrammaticNew Source Review Malcolm C. Weiss Jeffer, Mangels, Butler & Marmaro LLP 1900 Avenue of the Stars Los Angeles, CA 80067 (310) 712-6822 mweiss@jmbm.com 3748292 November 2, 2005

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