Regulatory Update Alan De Salvio Deputy Director Mojave

Regulatory Update Alan De Salvio Deputy Director – Mojave Operations

MDAQMD Background � $8. 5 � 43 million budget full time staff (including 7 compliance and 6 permitting) � Contract services to AVAQMD

MDAQMD Background � Regulatory authority over 600 companies with 1200 facilities holding 4200 permits � 40 Title V facilities � ~7 million square feet of cannabis cultivation, manufacturing, extraction, distribution and transportation has received land use permits � 85 cannabis related permits issued to date � 16 Cannabis Odor Compliance Plans

MDAQMD 2019 Board Rule Actions � Rule Amendments: Rule 501 – Procedures before the Hearing Board (and rescinded all of Regulation V - Procedures before the Hearing Board and Regulation VIII – Orders for Abatement Rule 102 – Definition of Terms; Rule 219 – Equipment Not Requiring a Permit; Rule 300 – Permit Fees Rule 301 – Other Fees Rule 302 – Hearing Board Fees Rule 312 – Fees for Federal Operating Permits Rule 401 – Visible Emissions Rule 900 – Standards of Performance for New Stationary Sources (NSPS) Rule 1000 – National Emission Standards for Hazardous Air Pollutants (NESHAP) Rule 1320 – New Source Review for Toxic Air Contaminants Rule 1520 – Control of Toxic Air Contaminants from Existing Sources

MDAQMD 2019 Board Rule and Plan Actions Adopted BARCT rule in compliance with AB 617, Rule 1157. 1 – BARCT Requirements for Boilers and Process Heaters Adopted 70 ppb Ozone Standard Implementation Evaluation: RACT SIP Analysis; Federal Negative Declarations and Emission Statement Certification

MDAQMD 2019 Other Board Actions � 36 grants for equipment replacements and upgrades totaling more than $5 million – farm equipment, mineral industry and aerospace � Continued program � 5% lawn and garden replacement fee increase effective 1/1/2020 � $0. 16 per square foot licensed cannabis effective 7/1/2019

MDAQMD 2020 Rule Development � Base year emissions inventory for 70 ppb plan (2017) in progress � Upcoming Rule actions: • Dust rule (403 to incorporate 403. 1, 403. 2 and tighter dust control plan requirements) • Address Federal approvability for Rules 1114, 1115, 1117, 1118 • New rule Adhesive Applications for missing CTG limits • Address Federal issues with NSR rules… we remain optimistic

AB 617 (and AB 197) Status � Emphasis on community emission reductions through grant process continues � District-wide installation of community-type sensors (more than 35 District Purple. Air sensors now permanently installed) � Emission inventory compliant with current 197 and 617 requirements – new CTR requirements in progress � BARCT implementation completed (cement kiln rule and boiler rules have been adopted)

Air Monitoring � Revamp in response to audit almost complete – abandoning physical filters completely � One portable particulate trailer ready and waiting; second in the works � We hope we don’t have to use them for smoke like 2017 (118 eight-hour ozone in June 17 due to smoke)

In conclusion � Keeping up with California legislation � Trying to satisfy Federal requirements � Strong community outreach and education effort, including support of Mojave Environmental Education Consortium (MEEC), science fairs, poster contest, solar cook-off, Exemplar awards, health advisories (high winds and wildfires)