The U.S. Environmental Protection Agency (EPA) established National Ambient Air Quality Standards (NAAQS) for various air pollutants to protect human health. Areas that do not meet the standards for specific pollutants are designated as “nonattainment areas” for those pollutants. There are six designations for classifying nonattainment based on the extent to which a pollutant concentration exceeds the standard: Marginal, Moderate, Serious, Severe 15, Severe 17, and Extreme.
Coachella Valley was previously classified as a Severe-15 nonattainment area for the 1997 8-hour Ozone NAAQS, with a goal to have been in attainment by mid-2019. Despite improvements in ozone air quality, higher ozone levels were experienced in 2017 and 2018. EPA granted South Coast Air Quality Management District's (SCAQMD's) request to voluntarily reclassify the Coachella Valley from Severe-15 to Extreme for the 1997 8-hour Ozone NAAQS. This reclassification requires amendments to the following SCAQMD regulations:
- Regulation XIII - New Source Review (NSR)
- Regulation XX - RECLAIM
- Regulation XXX - Title V
The proposed amendment to Regulation XIII would lower the threshold for a Major Polluting Facility from 25 tons per year to 10 tons per year of VOC or NOX. This may mean that more facilities within Coachella Valley get pulled into the Major Polluting Facility classification. Additionally, the proposed amendment would change the threshold for a Major Modification under NSR in Coachella Valley from 25 tons per year to 1 pound per day of VOC or NOX. SCAQMD currently uses a 1 pound per day VOC and NOx Best Available Control Technology (BACT) applicability threshold for modifications. Therefore, there are no foreseeable impacts to facilities from the altered Major Modification threshold.
The proposed amendment to Regulation XX would lower the threshold for a Major Modification under RECLAIM in Coachella Valley consistent with the federal definition of Major Modification. Again, SCAQMD currently uses a 1 pound per day VOC and NOX BACT applicability threshold for modifications. Therefore, there are no foreseeable impacts to RECLAIM facilities in Coachella Valley.
The proposed amendment to Regulation XXX would lower the threshold for enrollment in the Title V program from a potential to emit (PTE) of 25 tons per year of VOC or NOX to 10 tons per year of VOC or NOX. The Title V program requires Major Polluting Facilities to obtain a Title V operating permit, operate in compliance with that permit, and certify annually and semi-annually their compliance with permit requirements.
There are two facilities within Coachella Valley that have been identified to have a PTE between 10 and 25 tons per year of VOC or NOX. Therefore, under the proposed amendments these facilities would be classified as Major Polluting Facilities and subject to Title V requirements.
If your facility:
- emits VOC or NOX: review your PTE to assess whether these proposed amendments may impact your facility;
- is considering any modifications or facility upgrades that would result in an emissions increase: there may be additional control requirements to comply with; and/or
- is near the 10 tons per year threshold: you can take a cap on total facility VOC or NOX emissions or make concurrent facility emission reductions to avoid triggering any additional requirements.
Preliminary draft documents for the proposed rule amendments under these regulations are posted on SCAQMD's website.
For questions specific to your facility, please contact Emma Price.