On 6/20/01, I attended a Bay Area Air Quality Management District (BAAQMD)
hearing regarding stationary internal combustion engines (including Diesel
Standby Generators).

The proposed regulation was "framed" in the following context:
BAAQMD is the only district in CA not now requiring permits for standby
engines 3-5k units are estimated in Bay Area, Avg. 350hp

While the previous hearings (5/11) had promised the final draft by 5/20/01,
the newest revisions were posted on Tuesday (6/19).  Evidently there were
last minute changes and a conclusion that the appropriate California
Environmental Quality Act (CEQA) document needs changes.  They may have
another workshop, possibly before the August 1st meeting, although it wasn't
clear if they can get the proper notices and input prior to that time.

The item was continued - Possible Final Action To Be Taken on August 1,
2001, although it may be continued again.

The new revisions are attached:
 <<r0908dr5.pdf>>  <<r0201dr6.pdf>>
They can be fount at:   http://www.baaqmd.gov/ruledev/reg-pmt/r0201ph1.htm

MY CONCLUSIONS AND QUESTIONS/CONCERNS THAT REMAIN
* It is doubtful that any rule change would be approved in time to provide
relief for this summer (2001).
* We remain under the old rule exemption for fixed standby generators that
has a limit of 200 hours per year emergency runtime and 100 hours testing
maximum.
* In Regulation 2, Rule 1 - 114.2 - 2.3 states exemption for "Portable
internal combustion engines and standby internal combustion engines which
are at a location for less than 72 consecutive hours".  Does this mean the
previous guideline of BAAQMD not regulating mobile sources unless in place a
year is now just 72 hours?

I am reviewing the proposed changes further and plan to participate in
future workshops and the hearing on August 1, 2001.

...Steve
Stephen Motzko, CSP
Solectron Corporate EHS Manager
Phone:  510-661-3979
Fax:  510-661-3992
email:  stephenmotzko@ca.slr.com


 - r0908dr5.pdf
 - r0201dr6.pdf