Compliance dates for emission limits are based on the date of equipment manufacture and emission limits are applicable to older equipment first.
Owners of equipment are provided at least 15 years before they must modify or replace existing equipment to meet the new emission limits. A time table may be changed after the Rule 1147 workshop on these dates.
Rule 1147 also established test methods and provides alternate compliance options including a process for certification of equipment NOx emissions through an approved testing program. Other requirements include equipment maintenance, fuel and time meters and recordkeeping.
Proposed amendments and objectives to the rule caused the AQMD staff to recommend delaying of the NOx emission limit compliance dates for existing (in-use) permitted equipment.
The proposed rule also limits the requirement for gas fuel meters to equipment that comply with the NOx emission level using pounds per million Btu. Staff is also proposing to eliminate the requirement for time meters if the gas line is fed directly to the paint booth and has no other operating equipment on it.
PAR 1147 will result in delayed emissions reductions from equipment subject to this rule. PAR 1147 is expected to result in a maximum of 1.4 tons per day of NOx emission forgone in 2011. However, PAR 1147 would achieve the same reductions as the existing rule by 2014.
Pursuant to the California Environmental Quality Act (CEQA) and SCAQMD’s Certified Regulatory Program (Rule 110), the SCAQMD is preparing a Notice of Preparation/Initial Study (NOP/IS) for the proposed amendments to Rule 1147.
The NOP/IS serves two purposes: 1) to solicit information on the scope of the environmental analysis for the proposed project, and 2) to notify the public that the SCAQMD will prepare a Draft Environmental Assessment (EA) to further assess potential environmental impacts that may result from implementing the proposed project.
The proposed project may have statewide, regional or area-wide significance; therefore, a CEQA scoping meeting is required (pursuant to Public Resources Code §21083.9(a)(2)). The public workshop will serve as a CEQA scoping meeting for the proposed actions.
Comments received at the public workshop/CEQA scoping meeting on the environmental analysis will be considered when preparing the EA. When released, the NOP/IS will be available for public comment and review for 30 days.
A sidebar coalition that has been developed comprising representatives from different associations including the California Autobody Association (CAA) was also present at the workshop. The coalition is hoping to communicate directly with members of the AQMD’s Board about their concerns with Rule 1147.
“Rule 1147 is just not going to work in its current form,” said Linda Holcomb, representing the CAA.
“The NOx that the autobody industry emits is very minimal ... we feel we should be exempt from this rule,” said Holcomb.
Holcomb went on to say that only an estimated half of paint booth in the AQMD district have heaters, and maybe 10% of those are old paint booths from the ‘80s (which would need to be retrofitted to meet new guidelines). She also said that waterborne paint spraying systems have drastically cut down the amount of time body shops use their heaters for curing cars, so in essence the shops have greatly reduced their NOx emissions already.
“To me they’re really barking up the wrong tree,” said Holcomb.
Upon completion of the public review and comment period for the NOP/IS, responses to comments received relative to the NOP/IS will be prepared and incorporated into the Draft EA that will be subsequently prepared and circulated for a 45-day public review and comment period.
Comments and suggestions regarding the CEQA analysis for the proposed project should be directed to: Ms. Barbara Radlein - CEQA Section Planning, Rule Development & Area Sources SCAQMD 21865 Copley Drive Diamond Bar, CA 91765. Phone (909) 396-3324. E-mail: firstname.lastname@example.org.