South Coast Air Quality Management District’s (SCAQMD) Compliance Requirements Jayne Joy, P.E. June 20, 2017

SCAQMD Compliance Requirements Agenda Key Areas of Impact from SCAQMD Compliance Requirements Contractor’s Fleet for Construction Internal Combustion Engines and Flares Diesel Generators On-Road Heavy Duty Vehicles Recommendations

Key Areas of Impact from SCAQMD Compliance Requirements

Areas of Impact from SCAQMD Compliance Requirements SCAQMD regulates the air emissions sources in the South Coast Air Basin (SCAB) SCAB is in severe non-attainment for ozone and its precursors Non-attainment status sets the air emission reductions extremely low SCAQMD emission reductions are set to meet the Clean Air Act Ozone targets The main contributions of air emissions in SCAB are mobile sources. Typically SCAQMD does not regulate most mobile sources except for vehicle fleets that are within SCAQMD such as EMWD’s Heavy Duty vehicle fleet The recently adopted 2016 Air Quality Management Plan (AQMP) sets the path for new and amended regulations to achieve the targets SCAQMD will implement the AQMP through ruling making in the next few years Key areas for discussion of current and future impacts include: Contractor’s Fleet for Construction Internal Combustion Engines and Flares Diesel Generators On-Road Heavy Duty Vehicles From 2016 AQMP, figure shows projections indicating that the region must reduce regional NOx emissions by an additional 45 percent in 2023 and an additional 55 percent in 2031 to attain the 1997 and 2008 8-hour oxone NAAOS. Air Emissions Reduction Targets

Contractor’s Fleet for Construction

Contractor’s Fleet for Construction California Environmental Quality Act (CEQA) evaluates the air quality emissions of a project to an air quality threshold of significance Mitigation measures are required when the threshold is exceeded, such as: Requiring the use of 2010 and newer diesel haul trucks, e.g., material delivery trucks and soil import and export Requiring that all on-site construction equipment meet EPA Tier 3 or higher emissions standards These mitigation measures are used throughout California and are not strictly a SCAQMD criteria Contractors, especially the larger contractors, are replacing their construction equipment, as needed, with lower emitting units Small contractors, who do not perform as much earthwork may have older equipment, affecting their bids by 5% to 10% due to added rental costs to meet emission requirements Note: EMWD OFF-ROAD VEHICLES ARE LOW USE AND DO NOT HAVE TO COMPLY WITH THESE REGS.

Internal Combustion Engines and Flares

Internal Combustion Engines WHAT HAS BEEN DONE: Many IC engines were in place at EMWD. The effects of amending Rule 1110.2 in 2008 include: Greatly increased the monitoring and reporting requirements, emissions testing shifted from an every three year test to weekly and monthly tests, and daily monitoring Required retrofits on engine control systems with the best available control technology and some continuous monitoring Reduced the emissions limit for biogas engines to an infeasible and nearly unachievable level for EMWD biogas systems EMWD response included: Hiring new staff and added contract support to meet maintenance, monitoring, and reporting requirements Awarding construction contracts to retrofit 34 engines Pursuing biogas control technologies for three engines, including NOxTech and Tecogen Installing Fuel Cell as an alternative power source

Internal Combustion Engines WHAT WE ARE DOING: The added costs imposed by Rule 1110.2 to operate and maintain engines has tipped the economic scale away from IC engines. In response, EMWD has: Electrified 8 engines Removed 1 engine from service Converted 1 engine to emergency use Continued with the enhanced maintenance, monitoring and reporting program for 52 engines Under Rule 1110.2, Biogas engines were given additional time to achieve compliance (January 2019) However, a sound cost-effective, technical solution to control emissions is not available. In response, EMWD has: Initiated a Biogas Utilization Study to help us determine the best approach to utilize biogas at EMWD facilities Continued the Tecogen demonstration project using biogas at MVRWRF using the fuel cell’s biogas clean-up system Tecogen can also be used on natural gas engines, but they must be rich burn engines

Internal Combustion Engines WHAT WE HAVE PLANNED: Continue with electrification. Electrify the IC Engines per EMWD’s Energy Management Plan Removal of 25 engines in the next 10 years The benefits of this approach are: Significant reduction in the maintenance, monitoring and reporting requirements driven by SCAQMD regulation Electrifying the blowers for the RWRF will improve operational flexibility for the plants. Gas driven blower engines have been challenging to operate due to the high maintenance and engine wear associated with burning biogas and the challenges achieving lower emissions using biogas. EMWD plans to implement the recommendations from the Biogas Utilization Study. The study is evaluating the feasibility and practicality of a: Cogeneration Facility Pipeline Injection System in the grid

Internal Combustion Engines Summary of IC Engine Costs ($000) Number of EMWD Permitted Prime IC Engines Past (Yr. 2012) Present (FY 16/17) Future 62 52 27 PRIME IC ENGINES: Rule 1110.2 Cost Impacts ($000) Subcategory Past Present Future SCAQMD O&M Costs 1 $ 7,408 $ 508 $ 413 Biogas Costs2 $ 4,387 $ 691 $ 28,000 Water Enterprise Electrification 3   $0 $ 15,033 $ 4,312 Annual Engine Emission Testing Costs $ 126 $ 148 $ 137 Total ($000): $ 11,921 $ 16,380 $ 32,862 Notes: Past O&M include multi-year costs: 2008-2016 Future costs are planning level estimates and do not include the value of biogas Electrification based on Energy Management Plan

Annual Operations & Maintenance (2016) Flares FLARES: Biogas flares are essential to ensure that excess biogas is effectively destroyed SCAQMD permits flares and is expected to pursue a new rule impacting flares. It could include early replacement of the flares with higher than the current best available control technology (BACT) EMWD has five stationary flares. Three of the five do not meet BACT One flare which meets BACT requires increased maintenance Rulemaking is anticipated Fall 2017 SCAQMD PLANS: Early replacement of flares has a negative effect on equipment investments EMWD’s existing flares are estimated to last for at least ten more years New flares have higher maintenance costs Flares Costs Category Cost ($000) Initial Capital Costs ($1.5M per Flare) $ 7,500 Annual Operations & Maintenance (2016) $ 60

Diesel Generators

Number of Permitted EMWD Stationary Diesel Generators EMWD uses Diesel Generators at most of its facilities as back up power during brown outs, power outages and major unforeseen events. They are an essential tool for EMWD to ensure that we can move water and pump wastewater during major events. Over the next 10 years, EMWD expects to add at least 8 emergency generators as existing facilities are electrified SCAQMD has identified that diesel emissions are a risk to public health, requiring Diesel Particulate Filter (DPF) when located near sensitive receptors. Ten of our generators have DPFs SCAQMD PLANS SCAQMD discourages the use of the diesel generators and is recommending rules to require the use of alternative technology such as, fuel cell or battery. Essential public facilities may be exempt Risk of not being able to use Diesel Generators Reliability of service for water and wastewater especially during a major event Alternates to a diesel generator may not work at remote facilities Number of Permitted EMWD Stationary Diesel Generators Past (Yr. 2012) Present (FY 16/17) Future 58 67 75

On-Road Heavy Duty Vehicles

On-Road Heavy Duty Vehicles EMWD has an on-road heavy duty fleet that is comprised of 76 vehicles. These vehicles are used by EMWD for operations, maintenance and emergency response situations. Examples of these trucks include vacuum trucks, cranes, semi-tractors, dump trucks, utility trucks, boom trucks, cement mixers and water trucks. SCAQMD PLANS: EMWD has looked into near-zero emission vehicles, however, new purchases have been deferred due to the lack of support infrastructure in our service area. The SCAQMD Regulation for these vehicles require public/commercial fleets of 15+ vehicles to purchase alterative fueled vehicles when adding/leasing a new vehicle to their fleet Typically SCAQMD doesn’t regulate mobile sources but the above legislative authority has been granted by the Health and Safety Code The future AQMP requirements could be challenging as mobile sources are the most significant contributor to ozone non-attainment The 2016 AQMP instructs SCAQMD to pursue legislative authority to require public fleets to expeditiously convert to zero emission heavy duty vehicles. In the board hearing this was changed to zero and near-zero emission vehicles

On-Road Heavy Duty Vehicles EMWD PROGRAM: EMWD has five CNG trucks budgeted for FY 16/17 EMWD estimates 19 additional CNG trucks will be purchased over the following nine years EMWD will need to construct a fueling facility to support the CNG fleet Category On-Road Heavy Duty Fleet Past (Yr. 2012) Present (FY 16/17) Future Diesel 54 38 10 Gasoline 25 34 33 Propane 4 CNG  0 0  24 Total Vehicles* 83 76 71 On-Road Heavy Duty Fleet: Estimated CNG Costs Category Estimated Cost CNG Fueling infrastructure $ 1,250,000 CNG Maintenance infrastructure $ 400,000 Added Cost for CNG vehicle purchases* $ 1,560,000 TOTAL $ 3,210,000 *Estimated inventory

Recommendations

Recommendations RECOMMENDED RESPONSES TO SCAQMD PLANS: As SCAQMD proposes their new or revised regulations, EMWD will have an opportunity to comment on these regulations through the public review process and at workshops. Focus should include: New rule that governs flares: Do not support the early replacement of the flares, to protect our investments Due to intermittent use, the replacement of existing flares will not result in a measureable benefit to the regions air quality New rule that eliminates the use of diesel generators: Essential public agencies could be exempt from this rule. Strongly recommend that special districts are designated as essential public services agencies The alternatives to generators have not been proven effective for special district services. EMWD must have the ability to run remote facilities effectively and provide water and wastewater services at all times, especially during major events such as earthquakes, fires, etc. New rule requiring public agencies to expedite the conversion of On-Road Heavy Duty Vehicles to near-zero, that includes CNG vehicles Do not support expedited conversion of the vehicles to protect our investments Do not support conversion of public agencies to zero-emission vehicles to protect from potential future costly expenditures in the CNG (near-zero) vehicles and infrastructure for our heavy duty fleet

Contact Information Jayne Joy, P.E. Environmental & Regulatory Compliance Director (951) 928-3777 Ext. 6241 Email: joyj@emwd.org