The South Coast Air Quality Management District (“South Coast AQMD”) is considering a proposed rule that would reduce nitrogen oxide (NOx) emissions and limit carbon monoxide emissions from commercial food ovens that require a South Coast AQMD permit for:
- REgional Clean Air Incentives Market (“RECLAIM”)
- Former RECLAIM
- Non-RECLAIM Facilities
The South Coast AQMD addresses the air quality control region encompassing Los Angeles, California.
The air quality control region is classified as severe nonattainment for the ozone National Ambient Air Quality Standard.
The proposed amended rule (1153.1) would address emissions of oxide of nitrogen from commercial food ovens. Permitted commercial food ovens would be subject to eventual zero-emission NOx limits where technology has been identified as technically feasible and cost-effective.
This rule would be applicable to manufacturers and operators of commercial food ovens, roasters, and smokehouses producing food and beverage products (NAICS 311 and 312).
A draft South Coast AQMD staff report states that 97 facilities with a total of 218 commercial food ovens regulated by PR 1153. 1 were identified. To meet the rule, the oven would have to shift to a zero-emission electric device once it is subject to this provision.
As would be expected, commercial bakeries in the area and their consultants have identified potential issues. These concerns include:
- Cost-effective analysis
- Electric oven availability
- Product quality and employee safety
- Electricity upgrades and electric load availability
- Timeline for regulatory review
- Emission leakage
Environmental organizations support the proposed rule, arguing:
- It is cost effective
- Disagreement with projections of natural gas future cost
- Health impact should be a focus
Links to the following documents can be downloaded below.
The Between the Lines blog is made available by Mitchell, Williams, Selig, Gates & Woodyard, P.L.L.C. and the law firm publisher. The blog site is for educational purposes only, as well as to give general information and a general understanding of the law. This blog is not intended to provide specific legal advice. Use of this blog site does not create an attorney client relationship between you and Mitchell Williams or the blog site publisher. The Between the Lines blog site should not be used as a substitute for legal advice from a licensed professional attorney in your state.