3
including CEQA review. The process may be much shorter where CEQA exemptions are used, or it may
be longer if there is public opposition or a lead agency that is unfamiliar with the technology.
2.2 Air Quality Permits
Every stationary source (equipment) that emits air contaminants must have an air permit from one of
California’s thirty-five independent air districts, unless an exception applies. Hydrogen is not a regulated
pollutant, so the storage of hydrogen fuel in tanks will not, itself, likely require an air permit. Thus, stations
that merely accept hydrogen fuel deliveries generally will likely not need air permits for hydrogen fuel
storage tanks, as they will have no regulated emissions.
8
However, if a hydrogen fuel dispensing station
uses on-site production equipment (such as steam methane reformers) that emits contaminants, an air
permit may be required, unless an exemption applies. These permits typically impose conditions that
control and limit emissions. Each air district has its own requirements, but those of the South Coast Air
Quality Management District (SCAQMD) in the Los Angeles area are typically the most stringent
statewide.
9
Steam methane reformers that are part of some hydrogen fuel stations use gas-fired burners,
and the SCAQMD requires permits for gas-fired burners operating at or above 2 million BTU per hour.
10
However, today’s hydrogen fuel stations do not operate on that scale. Based on our review, it appears
that some existing hydrogen fuel stations in the SCAQMD were given exemptions for their on-site
production equipment, and did not require air permits.
11
8
Personal communication with Leslie Goodbody, California Air Resources Board (CARB), Sustainable
Transportation Technology Branch (Oct. 17, 2013), (916) 323-
2961 and
[email protected];
see also
personal
communication with Randy Matsuyama, South Coast Air Quality Management District (SCAQMD), Air Quality
Engineer (Oct. 18, 2013), (909) 396-2551.
9
See id.
10
South Coast Air Quality Management District (SCAQMD) Rule 219(b)(2);
see also
personal communication with
Leslie Goodbody, California Air Resources Board (CARB), Sustainable Transportation Technology Branch (Oct. 17,
11
See, e.g.
, South Coast Air Quality Management District (SCAQMD), Facility INformation Detail (FIND),
http://www3.aqmd.gov/webappl/fim/prog/appdetail.aspx?appl_nbr=515614 (last visited Feb. 18, 2015) (Newport
Beach station); SCAQMD, Facility INformation Detail (FIND),
http://www3.aqmd.gov/webappl/fim/prog/appdetail.aspx?appl_nbr=484970 (last visited Feb. 18, 2015) (Burbank
station). Additional projects in the jurisdiction of SCAQMD are under development, and air permitting will be handled
on a case-by-case basis. Generally, if the combustion equipment associated with the hydrogen fueling station is rated
less than 2,000,00 BTU/hr, then it would not require a permit. Personal communication with Merrill Hickman, Senior
Air Quality Engineer, SCAQMD Operations Team (Feb. 20, 2015), (909) 396-2676 and
[email protected].