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can be their own CEQA Lead Agency for
a project, jurisdictional permitting per-formed
by regional air agencies follows
its own set of rules and requirements for
functioning as a Lead Agency. Projects
must demonstrate compliance with these
agency policies and procedures before a
permit to construct is issued. A project that
was approved pursuant to CEQA with or
without significant impacts may find that
when the regional air district performs
its permitting analyses, it can’t be per-mitted.
Necessary changes can affect the
project design basis resulting in schedule
delays, changes to equipment design, and
cost increases.
As an example, consider a proposed
project with air emissions of a pollutant
concentration that have been estimated
based on an air blower capable of a vari-able
air flow rate. Under CEQA, the proj-ect
must evaluate environmental impacts
of the proposed project under normal
operating conditions, which may be as-sumed
to be at an average flow rate. How-ever,
at an average rate, emissions would
be less than the potential emissions at a
peak flow rate as would be used by the air
permitting agency for the purposes of de-termining
emissions control requirements,
air dispersion modeling, emission offsets
requirements, and health risk assessment.
The project proponent would be better off
using the maximum designed flow rate in
the CEQA document than to evaluate a
lesser “normal operating” project because
this would allow for the CEQA analysis
to be contested in the future by either the
permitting agency or the public.
Changes
Air quality impacts are often the main
aspect of the environmental review process
for industrial projects, including those of
water treatment facilities. In our experience,
assuring that the equipment and/or activi-ties
analyzed during the CEQA review pro-cess
remain consistent with (or more than)
what sources will need to obtain an air
permit, is crucial. In general, air quality dis-tricts
in California cannot issue permits un-til
the CEQA process is completed and the
sources and emissions to be permitted are at
least as much as the emissions analyzed in
the CEQA document, whether it be an EIR
or MND.
Changes in equipment design or
emissions quantification methodology can
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