With every ATC application, the District is required to perform an emissions evaluation which documents the proposed equipment, quantifies the potential emissions, and documents compliance with all applicable rules and regulations. The ATC is then drafted with conditions that ensure compliance with the applicable requirements.
The following are items that are considered during the review process:
|New Source Review (NSR)
When a company applies for an Authority to Construct (ATC) permit for new equipment or to modify existing equipment already under Permit to Operate (PTO), the application must be reviewed for compliance with Rule 3.4 New Source Review (NSR). Although the nuances of NSR are intricate, there are two key elements of NSR: Best Available Control Technology (BACT) and Offsets.
|Best Available Control Technology (BACT)
BACT is the requirement that certain air pollution sources install equipment or employ administrative practices that will result in the lowest achievable emission rate. BACT is defined as the most stringent emission limitation or control technique which:
- Has been achieved in practice
- Is contained in any State Implementation Plan (SIP) for the particular class or category of source, unless the owner of the source demonstrates that the limitation is not achievable, or
- Is any other emission limitation or control technique, including alternate basic equipment or process or changes of control equipment, found by the Air Polluton Control Officer (APCO) to be technologically feasible for such class or category of sources and cost effective as determined by the APCO.
BACT applicability calculations are performed individually for each pollutant and for each separate emissions unit (as opposed to a facility wide basis).
Offsets are determined on a stationary source (facility) wide basis and are the system that allow for new small and medium size businesses to be installed and still allow the District to achieve overall emission reductions. The concept is that any stationary source is allowed to emit a certain amount of air pollution. Any new, large business that wants to emit more than the threshold or any existing business that wants to increase emissions above the threshold, must mitigate (offset) their emissions by purchasing offsets (Emission Reduction Credits) from other sources that have previously reduced their actual emissions and banked those emission credits.
|Emission Reduction Credits (ERC)
District Rule 3.5 Emission Reduction Credits provides an administrative mechanism for quantifying, adjusting, and certifying surplus emission reductions for later use as offset; or transfer to other sources. ERCs are available when a facility reduces actual emissions by either installing control equipment or ceasing operations. What is available to be banked is the amount that the source actually emitted in the recent past (actual emissions), not the amount they were permitted to emit (permitted emissions).
Once banked, the ERC's are held by the companies and can be traded on the open market. The District does not hold ERC's (except for a priority reserve account for essential public services) and does not set the price or value of credits. The District does act as the registrar and any time that credits are sold, the seller must submit an application for the District to transfer the credits and issue new certificates. The District is also required to track purchase price of all ERC transactions and report to the State annually.