The need to revise and adopt new emission reduction credit rules for Imperial County is due in large part to the designation of Imperial County as a non-attainment area for the 24hr PM2.5 federal standard. As part of the revisions to the 2006 24hr PM2.5 federal standard, Air District's were required to make significant changes to existing New Source Review (NSR) permitting programs. NSR permitting program requirements were created by Congress within the 1970 Amendments to the Federal Clean Air Act (CAA). They are implemented by the United States Environmental Protection Agency (US EPA) through air quality permitting regulations. These NSR programs are the fundamental backbone to any industrial type source, such as power producing companies, manufacturing companies to name a few. Without an approved NSR program these industrial type sources cannot operate nor can they make needed modifications to their operations. The Imperial County NSR program was updated in 2013 meeting federal requirements.
A very critical component for industrial type operations to continue improving and moving forward requires what are known as "Offsets". NSR programs cannot allow for net emission increases therefor industrial type operations must demonstrate net emission reductions. Net emission reductions are achieved by requiring the new or modified source to comply with the Lowest Achievable Emission Rate (LAER) for the nonattainment pollutant(s) or precursors and by requiring the source to offset the emissions, utilizing Emission Reduction Credits (ERC's). These ERC's must be "banked" using a standardized "banking system" that is recognized by both the California Air Resources Board (CARB) and the US EPA.
Pollutants that can be banked - PM10, PM2.5, NOx, VOC's, TOG's, CO and SOx to name a few.
What are Emission Reduction Credit's (ERC's)?
ERCs are creditable actual emission reductions that industrial type sources can generate at their facilities (traditional source type ERC). ERC's help meet the requirement imposed upon sources to demonstrate that there will be net emission decreases in nonattainment pollutants and precursors. Simply put, when a new facility chooses to locate in the area or needs to modify or install new equipment ERC's assist the source to meet its State and federal air quality obligations.
What is this Public Hearing for?
ERC's are in short supply and in high demand. In order to meet the CAA obligations and to help growth in Imperial County the Imperial County Air Pollution Control District has revised its existing ERC rules 214 and 215 as solely applying to traditional source type ERC (recognizable by the US EPA) and is simultaneously proposing two new rules which represent non-traditional sources of ERC's (recognized the CARB).