Rule 204 currently allows for the certification and utilization of emission reduction credits from permitted sources emitting PM, SO2, CO, NOX, and VOCs. Emission reduction credits that have been certified may be deposited into the Arizona Emissions Bank or utilized by a source. New sources can also utilize these credits, thus promoting industrial growth. Recently, the Arizona Department of Environmental Quality (ADEQ) amended the Arizona Administrative Code (AAC) to allow non-traditional sources to generate emission reduction credits. Thus, Maricopa County Air Quality Department (MCAQD) is proposing to revise Rule 204 to align with the changes made by ADEQ to allow for the generation, certification, and utilization of emission reduction credits from the following non-traditional sources:

  • Truck stop electrification
  • Electric standby equipped transport refrigeration units
  • Electric onsite equipment (including replacing gas or diesel equipment for electric)

These sources will help generate additional emission reduction credits which can be utilized by larger projects which previously may not have been able obtain permits due to insufficient credits in the Arizona Emissions Bank. Additionally, offset integrity responsibilities have been added to Rule 204 for permitted sources that use certified credits from a planned generator or a regulatory generator. These responsibilities include actions that must be taken if an offset shortage occurs. The proposed revisions to Rule 204 are scheduled for adoption by December 2019. You can view the rule revisions on the MCAQD website here. Trinity is available to assist clients in obtaining these credits; please contact Laura Cash at the Phoenix office at (602) 274-2900 or lcash@trinityconsultants.com for more information.