APPS-CIT_MINUTES_20141211-final

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Air Pollution Permit Streamlining (APPS) Committee/
Compliance Improvement Team (CIT) Joint Meeting
Notes for December 11, 2014
The sign-up sheet is attached as a PDF document. Note that Tom Weeks, Jon Adams, and Aidan Hanley
also attended.
Two modifications to the September 25, 2014 minutes.
 In the second paragraph on the first page (pertaining to Citizen Access), Aidan Hanley clarified
that the citizens seeking permits for solar projects did get into Citizen Access, but that the
applications were directed to the IT staff rather than the permit processing staff.
 In the third-to-last paragraph on the second page (pertaining to the OEHHA risk assessment
modifications), Tom Weeks did not recall mentioning any increased factors for other cancer risk
from non-inhalation pathways, and recommended to delete the last phrase of the second sentence.
The new sentence would read, “Inhalation cancer risk estimates will increase by approximately
three times.”
In terms of Citizen Access and online services, Dan Knowlton of APCD indicated that electronic fund
transfers and e-checks will likely be enabled, but that credit card payments still face hurdles, primarily
due to the large fees associated with their use. However, Jon Adams indicated that credit cards may be
used for small dollar transactions where the size of the fee is not as much of an issue. Aidan Hanley
indicated that additional features will be added to Citizen Access, and that more training will be held as
the system expands and evolves.
The analysis for the update Rule 40 (Fees) has gone through an internal county review, and public
workshops will be held in early 2015. Fees will likely increase 5 to 6% over the current fees (enacted in
2011).
Online permit applications can now be submitted for five types of coating permits. APCD is in the
process of adding additional types of permits starting with emergency standby engines.. Marine coating
permits are still being beta-tested, but so far the system is working well.
Jon Adams indicated that an online payment working group has been convened and that an internal
meeting was held prior to bringing in external representatives. APCD is soliciting interest to participate
in this group. (The Navy has expressed interest.) Jon Adams also indicated that APCD is currently in the
process of scanning their files with the goal of creating a PDF library.
Tom Weeks presented permit processing data in both spreadsheet and bar-graph form. Comments varied,
with the bar graph presenting trends on the monthly basis, while the spreadsheet provided more data, but
on a longer duration. Tom requested guidance on the format for future data presentations.
In response to the fee estimate/cost overrun item on the agenda, Tom mentioned that he analyzed fees for
recently issued permits and there were approximately equal number that needing an invoice versus
needing a refund. Tom committed to a review of common fee types to further refine the fee estimates
based on recent actual cost data. ,. In response to the quality assurance procedures for engineering and
HRAs, Tom indicated that there are several steps to check the results of HRAs. Following completion of
an HRA by staff (with the staff members own QA), the HRA is then checked by the Toxics Supervisor,
and the Senior Engineer. Tom also mentioned that HRAs done by the two new Toxics engineers are
being reviewed by more experiences staff prior to the Toxics Senior Engineer review.
In response to the update on the OEHHA HRA guidelines, Tom Weeks indicated that ARB will be
releasing the updated HARP model at the same time that OEHHA promulgates the new HRA guidelines
which is estimated to occur in February. Based on the guideline changes the District will need to update
prioritization procedures, Rule 1200 deminimis emission rates and District HRA guidelines.. The District
has not yet determined whether modifications will be required to Rules 1200 or 1210.
In response to a question about enforcement of the GHG refrigerant regulations, Mike Watt indicated that
Bay Area AQMD was doing this on behalf of ARB, but was not aware of any other district undertaking
this. Mike also indicated that the districts are negotiating with EPA over new compliance reporting
requirements. These impose new data collection requirements of debatable value.
Mike indicated that Tim Wolff had been promoted within the Compliance Division to fill a supervisor
vacancy.
Tom Weeks reported that the Rule 11 workshop report is wrapping up and is undergoing internal review.
The publication is anticipated in late February or early March, with a 30-day public comment period.
Based on the number of comments received to date, a second workshop is planned.
Jon Adams announced that San Diego County will be conducting customer service surveys beginning in
January. Jon also announced that APCD is looking to replace its emission inventory software, with a goal
of a system that will accept online entry of emission inventory data by the end of December 2015.
The next APPS/CIT meeting is scheduled for Thursday, March 12, at 8:30 AM.
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