After having reviewed public comment on its draft refinery rules 12-15 and 12-16, the Air District will present the revised proposed rules to the Stationary Source Committee. Draft Regulation 12-16 proposed a ‘crude throughput’ exemption that would allow refinery emission to increase when more oil is refined—as if business considerations, not health concerns, should govern refinery permits.
The draft regulation would also create an exemption allowing air pollutants to increase above a trigger level, up to its currently permitted limit (that is, if the refinery operated at 100% capacity). If it exceeded the trigger level, the refinery would need to perform a “causal analysis” and would have 2 years — that’s right, 2 years!— to correct the problem before facing fines. This is absurd.
What Rule 12 regulations do not do is to set an enforceable numeric cap on GHG emissions.
We are asking that the Stationary Source Committee direct staff to:
1.) remove the exemption for exceeding the trigger levels, and
2.) write into the regulation enforceable numeric caps on GHG emissions.
3.) establish a strict timeline for the implementation of these rules.
If BAAQMD fails to do that, as it has thus far, it will be ignoring its own mission statement, "To protect and improve public health, air quality, and the global climate."
On May 22nd, BAAQMD published Resolution 2015, and memorandum, Five Point Action Plan to Address Refinery Emissions (download both). The resolution and the memorandum are attachments to the Stationary Source agenda, items 4 and 5.
Links to Draft Resolutions 12-15 and 12-16 can be found here, on the BAAQMD website.
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