Gretel Smith

STAFF COUNSEL

HELPING HAND TOOLS

GRETEL.SMITH79@GMAIL.COM

October 17, 2012

VIA E-Mail: R9airpermits@epa.gov

Omer Shalev (AIR-3) 

U.S. EPA Region 9 

75 Hawthorne Street 

San Francisco, CA 94105-3901

Re: SPI-Anderson PSD Permit

 Permit No. SAC 12-01

Dear Mr. Shalev:

I am the staff counsel for Helping Hand Tools. Helping Hand Tools is a California non-profit 

corporation dedicated to protecting and improving air quality. Below please find Helping Hand 

Tools’ comments on the above mentioned matter.

Request to Extend Public Comment Period

Helping Hand Tools requests an extension to the public comment period. First, the EPA only 

provided an English version of the Public notice. A public notice in Spanish should also have 

been provided. Further, The EPA failed to demonstrate that it notified participants in the State 

action(s) about this proposed permit. The EPA failed to demonstrate that it provided Notice to 

the appropriate elected officials. Additionally, The public Notice fails to disclose any effect on 

air quality. A new notice should demonstrate the projects effects in relationship to the National 

Ambient Air Quality Standards or at least in gross pollutant weights. The EPA should reissue a 

Public Notice to the appropriate elected officials and members of the public who have expressed 

an interest in this project and other projects in the area. 

Second, the administrative record is quite extensive and requires more than a short thirty day 

notice period to come through the technical documents, evaluate the project and make 

appropriate constructive comments. 

For the reasons stated above, we request that: the public comment period be reissued; the EPA 

provides public notice in both English and Spanish; the EPA notice all appropriate elected 

officials and members of the public who have expressed interest in this project; and that the new 

notice Discloses the effect this project may have on air quality. 

Environmental Justice

In evaluating Environmental Justice issues, the AQIA fails to show any analysis to support its 

conclusion that no Environmental Justice issues exist. The AQIA should contain a complete

Environmental Justice evaluation to support the conclusion stated. 
Air Quality Impacts

Air Quality Monitoring used to Determine Background Ambient Air Quality

The AQIA states that the applicant utilized an Air Quality monitoring station 55.5 miles 

from the proposed site to determine background ambient air quality. Measurement of 

background ambient air quality must be done at or near the actual site in order to obtain accurate 

data that represents the actual air quality at the proposed site. 

The Permit Fails to Calculate the Cumulative Effect of Secondary Emissions

The cogeneration plant will receive its fuel from onsite and from offsite facilities via 

truck. The AQIA fails to analyze the cumulative impact on GHG and other emissions the trucks 

contribute to the overall emissions of the plant. The secondary environmental impact from 

transportation of the bio fuel and the removal of waste from the facility should be analyzed. 

Further, the AQIA does not analyze the cumulative impact of the secondary emissions from the 

kilns. The AQIA should analyze secondary emissions, BACT on the secondary emissions 

should be imposed, and the permit should include an emissions limit on the secondary emissions. 

BACT Analysis

The BACT Analysis fails in several respects. First, the analysis fails to review available 

technology. The BACT analysis fails to thoroughly analyze the SCR v. SNCR technologies. 

Further, the BACT analysis does not provide a broad analysis all potential BACT emissions 

controls available. Finally, the BACT fails to analyze Greenhouse Gas emissions from the 

natural gas used at the plant, erroneously relying upon the rules set forth in 76 FR July 20, 2011. 

The BACT analysis does not provide a no-cooling tower analysis. 

Boilers and Burners

The permit should require the technology that achieves the lowest possible emissions rate. Here 

it appears that EMxtm or the DLN would meet that goal. The technology exists to utilize those 

systems and a more thorough analysis of that technology should be completed. 

SCR v. SNCR BACT Analysis

Under the BACT analysis AQIA states that either the SCR or SNCR utilize ammonia. However,

the AQIA fails to establish the type of ammonia the SNCR or SCR will use. This is important 

because the transportation and storage of certain types of ammonia poses a public health risk. 

Additionally, ammonia slips vary from the types of ammonia utilized by the plant. The AQIA 

needs to include a more thorough analysis with regards to the ammonia usage, and storage of the 

ammonia. 

Step 4 of the BACT analysis comparing the SCR and SNCR fails to analyze comparative 

costs of facilities. The analysis should include a comparative cost to other facilities. 

Greenhouse Gas BACT Analysis

This cogeneration plant uses, natural gas, and biomass cellulose The temporary deferment of 

requiring BACT on Greenhouse gas emissions (GHG) for biofuels does not apply to plants that 

use natural gas. (76 FR No. 139, July 20, 2011; 40 CFR 52.21 (b)(49)(ii)(a); 40 CFR 

41.166(b)(48)(ii)(a).) The AQIA is silent as to what percentage of natural gas will contribute to 
the GHG emissions of the plant. At minimum a BACT analysis should be done on the GHG 

emissions from the use of the natural gas at the plant.

Cooling Tower

As stated in Mr. Simpson’s comments, the EPA should consider the kilns in the permitting 

process of this plant. The AQIA does not provide any analysis of the effects of not using a 

cooling tower. The AQIA should analyze a design that would eliminate the need for a cooling 

tower. 

Solar Component as BACT

The BACT analysis does not analyze the use of a solar component as BACT to offset some or all 

of the emissions resulting from the use of natural gas. The analysis should include the analysis 

of a solar component and the permit should require the use of a solar component. 

Emissions Deposition Impacts

The AQIA does not fully analyze the nitrogen deposition impact of the surrounding area. The 

AQIA should analyze the nitrogen deposition impacts and the effect the emissions impacts may 

have on the surrounding flora and fauna including the elderberry shrubs in the immediate vicinity

of the plant.

Conclusion

For the reasons stated above, Helping Hand Tools requests that the comment period be 

extended to cure the defects in public notice. Further, the AQIA fails to fully analyze cumulative 

air quality impacts of secondary sources. The background ambient air quality is based upon data 

55.5 miles from the proposed site which does not provide an accurate measurement of air quality

at the actual site. Additionally, the AQIA fails to provide a full BACT analysis of alternate 

technologies and emissions controls. Finally, the AQIA does not provide a full analysis of 

nitrogen deposition impacts or its effects on the surrounding elderberry shrubs.

In addition to the comments made above, all comments made by Rob Simpson on 

October 17, 2012 in this matter are incorporated by reference herein and enclosed with this letter.

Sincerely,

Gretel Smith, Esq.

Staff Counsel for Helping Hand Tools

(619)822-6262

Gretel.smith79@gmail.com

Enclosure

cc: Rob Simpson, CEO Helping Hand Tools
Rob Simpson comments on; 

PROPOSED PREVENTION OF SIGNIFICANT DETERIORATION 

PERMIT SPI - Anderson

For the forgoing reasons I request a public Hearing and extension of the public comment period. 

The record is too extensive to review in the allotted time period. The following clear errors are 

evident in the administrative record for this proceeding; 

The Modification fails to consider 

A No or reduced project alternative. The facility apparently requires 7 of the 23 megawatts 

electricity that it can generate. No state authority has, or is, required to make a determination of 

if this electricity, in this location, is beneficial to the system. The project will interfere with the 

development of superior solar and wind alternatives which would have created more jobs and a 

cleaner environment than this project. Clearly appropriately sized equipment 7/23 of the size of 

this one would result in reduced emissions. 

Since it is gas and wood burning proposal; the fuel mix should be considered in BACT analysis.

The BACT analysis fails to consider a different fuel mix. Increased gas use can raise the 

temperature and reduce emissions through more complete ignition. While the below discussion 

deals with GHG it should hold true for each pollutant.

In addition, EPA has observed that the application of methods, systems, or techniques to increase 

energy efficiency is a key GHG-reducing opportunity that falls under the category of “lowerpolluting processes/practices.” Use of inherently lower-emitting technologies, including energy 

efficiency measures, represents an opportunity for GHG reductions in these BACT reviews. EPA 

has encouraged permitting authorities to use the discretion available under the PSD program to 

include the most energy efficient options in BACT analyses for both GHG and other regulated 

New Source Review (NSR) pollutants...

“energy efficient measures may serve as the foundation for a BACT analysis...For facilities that 

are co-firing biomass with a primary fuel, the permitting record should provide a reasoned 

justification for basing BACT for greenhouse gases on a specific proportional allocation of 

fuels...See, In re: Northern Michigan University Ripley Heating Plant. PSD Appeal No. 08-02, 

Slip. Op at 18-23, 28 (EAB 2009) (remanding a permit for a co-fired electric generating facility 

where record did not contain justification for establishing BACT limits based on specific 

proportional allocation of wood and coal)...In cases where a permit applicant proposes to co-fire 

or combine biomass fuels with another primary fuel type, the list of BACT options should 

include the option of utilizing both types of primary fuels in different combinations. If the 

applicant proposes a specific proportional allocation or fuel mix (i.e., <5 percent biomass, >95 

percent fossil fuel) and believes other allocations should be eliminated from consideration in the 

BACT analysis for GHGs, the permit application should provide an explanation as to why the 

particular allocation desired by the applicant is necessary to achieve a fundamental business 

objective of the project. If the permit applicant is unable to demonstrate that a different allocation 
of primary fuels would fundamentally redefine the proposed source, the options at Step 1 should 

include varying allocations of the two primary fuels if the proportional allocation of fuels has the 

potential to affect the amount of GHGs emitted from the facility or the net atmospheric GHG 

concentrations.” http://www.epa.gov/nsr/ghgdocs/bioenergyguidance.pdf

A solar component should be considered in in the BACT analysis. A solar component would 

reduce all emissions by preheating the system or augmenting the electrical output. Solar energy 

is an inherently lower emitting, add on control technology. 

The BACT analysis fails to adequately consider energy efficiency options. There should be no 

need for cooling towers and their associated emissions to dissipate heat. The heat should be used 

in the existing Kiln or in a new Kiln or pre heater to warm the material before it enters the full 

temperature Kiln. The Permit should consider the existing Kiln as permitted equipment in 

context of this modification and the Kiln should be required to undertake a BACT analysis. The 

insulation, operation and even color of the Kiln will have an effect on its efficiency in reducing 

use of the associated emissions units.

A new cogeneration unit equipped with a stoker boiler is being proposed in order to burn 

additional clean cellulosic biomass fuel. Fuel will be generated on site from the lumber 

operations and delivered from other fuel sources to produce roughly 250,000 pounds per hour of 

steam. This steam be used to dry lumber in existing kilns for the lumber operation, as well as 

feed a turbine that will drive a generator to produce electricity for use on site or for sale to the 

electrical grid. A closed-loop two-cell cooling tower will be used to dispose of waste heat from 

the steam turbine. 4

EPA notes that energy efficiency is an option for inclusion in the set of control

options in the BACT analysis at Step 1 for all facilities. EPA agrees that this should become

standard practice for all facilities, and notes that the Bioenergy BACT Guidance does not intend

to remove energy efficiency as a control option for bioenergy facilities. 

http://www.epa.gov/nsr/documents/RTC_6-30_final_comb.pdf

The permit should identify the existing equipment and require its retirement. The administrative 

record demonstrates that the permit should at least require that the existing emissions units do 

not operate concurrently with the new units. The EPA has no authority to modify the underlying 

State permit. 

Handling and transport emissions. The analysis fails to consider the, perhaps collateral, 

emissions associated with the, primarily diesel powered, collection transport and on site 

handling of biomass. A permit condition should require that all associated equipment operates on 

Methane gas, or biomass power. 

The analysis fails to consider increased kiln emissions and other operational emission increases. 

Kiln and other facility emissions should be considered prior to final circulation of a draft permit. 
The project should be based upon a Comparison to the actual baseline instead of prior permit 

levels.

The air quality monitoring station, 50 miles from the site fails to represent conditions in the 

projects impact area. The EPA should require one year of local monitoring prior to consideration 

of a permit request. 

EJ The EPA failed to identify the environmental Justice community in the vicinity of the 

proposed project. This should be the first step in an EJ analysis in order for the EPA to conduct 

outreach and identify any stressors. It is inadequate for the EPA to skip this step and simply 

claim no harm to any potential community without notification. The EPA failed to issue a notice 

in Spanish.

Public notice participation The EPA failed to demonstrate that it notified participants in the State 

action(s) about this proposed permit. The EPA failed to demonstrate that it provided Notice to 

the appropriate elected officials. The EPA should reissue a Public Notice to the appropriate 

elected officials and members of the public who have expressed an interest in this project and 

other projects in the area. The public Notice fails to disclose any effect on air quality. A new 

notice should demonstrate the projects effects in relationship to the National Ambient Air 

Quality Standards or at least in gross pollutant weights. The Notice fails to alert the public of a 

reason to participate. 

The analysis is misleading because it does not disclose that the project intends to burn “urban 

wood” or post-consumer wood which would be more appropriately burned with a DLN Burner 

“In addition, there are 50,000 BDT of agricultural and urban wood

wastes available to SPI annually.” Application

DLN Burner 

With two or more DLN burners, the biomass combustion fuel would need to be pulverized and 

burned in suspension using wall-mounted burners. This presents a significant departure from 

SPI’s proposed boiler design where combustion occurs on a moving grate. DLN burners are 

designed to limit the amount of fuel-bound nitrogen that is converted to NOx during combustion, 

and are generally suited to boilers that burn wood waste containing a high percentage of resins, 

such as the waste from medium density fiberboard, plywood, or veneer operations. The emission 

rate with DLN burners is projected to be 0.35 lb/MMBtu.

The permit fails to require appropriate Ash bunker waste disposal. It does little good if the ash is 

collected and then left to blow away into the air or contaminate some other resource. 

EMX, SCR and Urea should be required.

Consideration of the McNeil facility are entirely speculative. If the project is to be excused from 

the BACT demonstrated at McNeil than additional analysis is required 

Although the McNeil Generating Station has demonstrated a lower NOx emission limit on a 

calendar quarterly basis, it has a short term NOx emission limit of 0.23 lb/MMBtu. Moreover, 
the possible economic incentives of the Class 1 Renewable Energy Credits in New England are 

difficult to quantify and not available to SPI- Anderson. This may allow SCR system to be more 

economically feasible for McNeil Generating Station and other proposed systems in the New 

England area than for SPI- Anderson in California.

EPA does not anticipate additional significant environmental or energy impacts from employing 

the SNCR or SCR technology. Both systems use ammonia as a reagent: anhydrous ammonia, 

aqueous ammonia, or urea mixed with water (which hydrolyzes in the hot exhaust to form 

ammonia). In the case of aqueous ammonia or urea mixed with water, additional fuel must be 

combusted to evaporate the water associated with the reagent. Moreover, energy is required to 

operate the injectors used by either technology to introduce the reagent into the exhaust. With 

either technology, the exhaust leaving the boiler stack will contain some small quantity of 

ammonia.

The PSD increment trigger date should have been when the original permit was issued.

“With respect to the PSD increment analysis for PM2.5, the applicable trigger date when the 

PM2.5 increments become effective under the Federal PSD program is October 20, 2011. The 

SPI- Anderson PSD permit application was determined to be administratively complete by EPA 

on October 4, 2010. However, EPA is requiring each source that receives its PSD permit after 

the trigger date, regardless of when the application was submitted, to provide a demonstration 

that the proposed emissions increase, along with other increment consuming emissions will not 

cause or contribute to a violation of the PM2.5 increments. Also the major source baseline, 

which precedes the trigger date is the date after which actual emissions increases associated with 

construction at any major stationary source consume PSD increment. That date is October 20, 

2010. With this PSD permit, SPI-Anderson would begin construction after this date. In general, 

for PM2.5, the minor source baseline date is the earliest date after the trigger date of a complete 

PSD permit application for a source with a proposed increase in emissions of PM2.5 that is 

significant. No source has triggered the minor source baseline date in the area at issue. Other 

than SPI- Anderson’s projected construction emissions, there have been no actual emissions 

changes of PM2.5 from any new or modified major stationary source on which construction 

commenced after October 20, 2010. Therefore, the only source to consume PM2.5 increment in 

the area is SPI- Anderson. The applicant considered only the allowable emissions increase from 

the SPI- Anderson project in the 24-hour PM2.5 increment analysis”33

The analysis must demonstrate the Nitrogen and other pollutant deposition on the adjacent 

Elderberry plants

SPI has confirmed that construction activities will not occur within 100 feet of the elderberry 

shrubs that are in the Pacific Gas and Electric power line Right of Way. The nearest construction

activity to the existing elderberry plants will be the erection of the electrical power poles at the 

existing electrical sub-station which are 137 feet away from the nearest elderberry shrub. 45 

Rob Simpson 27126 Grandview Avenue Hayward CA. 94542 Rob@redwoodrob.com
Rob Simpson comments on; 

PROPOSED PREVENTION OF SIGNIFICANT DETERIORATION 

PERMIT SPI - Anderson

For the forgoing reasons I request a public Hearing and extension of the public comment period. 

The record is too extensive to review in the allotted time period. The following clear errors are 

evident in the administrative record for this proceeding; 

The Modification fails to consider 

A No or reduced project alternative. The facility apparently requires 7 of the 23 megawatts 

electricity that it can generate. No state authority has, or is, required to make a determination of 

if this electricity, in this location, is beneficial to the system. The project will interfere with the 

development of superior solar and wind alternatives which would have created more jobs and a 

cleaner environment than this project. Clearly appropriately sized equipment 7/23 of the size of 

this one would result in reduced emissions. 

Since it is gas and wood burning proposal; the fuel mix should be considered in BACT analysis.

The BACT analysis fails to consider a different fuel mix. Increased gas use can raise the 

temperature and reduce emissions through more complete ignition. While the below discussion 

deals with GHG it should hold true for each pollutant.

In addition, EPA has observed that the application of methods, systems, or techniques to increase 

energy efficiency is a key GHG-reducing opportunity that falls under the category of “lowerpolluting processes/practices.” Use of inherently lower-emitting technologies, including energy 

efficiency measures, represents an opportunity for GHG reductions in these BACT reviews. EPA 

has encouraged permitting authorities to use the discretion available under the PSD program to 

include the most energy efficient options in BACT analyses for both GHG and other regulated 

New Source Review (NSR) pollutants...

“energy efficient measures may serve as the foundation for a BACT analysis...For facilities that 

are co-firing biomass with a primary fuel, the permitting record should provide a reasoned 

justification for basing BACT for greenhouse gases on a specific proportional allocation of 

fuels...See, In re: Northern Michigan University Ripley Heating Plant. PSD Appeal No. 08-02, 

Slip. Op at 18-23, 28 (EAB 2009) (remanding a permit for a co-fired electric generating facility 

where record did not contain justification for establishing BACT limits based on specific 

proportional allocation of wood and coal)...In cases where a permit applicant proposes to co-fire 

or combine biomass fuels with another primary fuel type, the list of BACT options should 

include the option of utilizing both types of primary fuels in different combinations. If the 

applicant proposes a specific proportional allocation or fuel mix (i.e., <5 percent biomass, >95 

percent fossil fuel) and believes other allocations should be eliminated from consideration in the 

BACT analysis for GHGs, the permit application should provide an explanation as to why the 

particular allocation desired by the applicant is necessary to achieve a fundamental business 

objective of the project. If the permit applicant is unable to demonstrate that a different allocation 

of primary fuels would fundamentally redefine the proposed source, the options at Step 1 should 
include varying allocations of the two primary fuels if the proportional allocation of fuels has the 

potential to affect the amount of GHGs emitted from the facility or the net atmospheric GHG 

concentrations.” http://www.epa.gov/nsr/ghgdocs/bioenergyguidance.pdf

A solar component should be considered in in the BACT analysis. A solar component would 

reduce all emissions by preheating the system or augmenting the electrical output. Solar energy 

is an inherently lower emitting, add on control technology. 

The BACT analysis fails to adequately consider energy efficiency options. There should be no 

need for cooling towers and their associated emissions to dissipate heat. The heat should be used 

in the existing Kiln or in a new Kiln or pre heater to warm the material before it enters the full 

temperature Kiln. The Permit should consider the existing Kiln as permitted equipment in 

context of this modification and the Kiln should be required to undertake a BACT analysis. The 

insulation, operation and even color of the Kiln will have an effect on its efficiency in reducing 

use of the associated emissions units.

A new cogeneration unit equipped with a stoker boiler is being proposed in order to burn 

additional clean cellulosic biomass fuel. Fuel will be generated on site from the lumber 

operations and delivered from other fuel sources to produce roughly 250,000 pounds per hour of 

steam. This steam be used to dry lumber in existing kilns for the lumber operation, as well as 

feed a turbine that will drive a generator to produce electricity for use on site or for sale to the 

electrical grid. A closed-loop two-cell cooling tower will be used to dispose of waste heat from 

the steam turbine. 4

EPA notes that energy efficiency is an option for inclusion in the set of control

options in the BACT analysis at Step 1 for all facilities. EPA agrees that this should become

standard practice for all facilities, and notes that the Bioenergy BACT Guidance does not intend

to remove energy efficiency as a control option for bioenergy facilities. 

http://www.epa.gov/nsr/documents/RTC_6-30_final_comb.pdf

The permit should identify the existing equipment and require its retirement. The administrative 

record demonstrates that the permit should at least require that the existing emissions units do 

not operate concurrently with the new units. The EPA has no authority to modify the underlying 

State permit. 

Handling and transport emissions. The analysis fails to consider the, perhaps collateral, 

emissions associated with the, primarily diesel powered, collection transport and on site 

handling of biomass. A permit condition should require that all associated equipment operates on 

Methane gas, or biomass power. 

The analysis fails to consider increased kiln emissions and other operational emission increases. 

Kiln and other facility emissions should be considered prior to final circulation of a draft permit. 
The project should be based upon a Comparison to the actual baseline instead of prior permit 

levels.

The air quality monitoring station, 50 miles from the site fails to represent conditions in the 

projects impact area. The EPA should require one year of local monitoring prior to consideration 

of a permit request. 

EJ The EPA failed to identify the environmental Justice community in the vicinity of the 

proposed project. This should be the first step in an EJ analysis in order for the EPA to conduct 

outreach and identify any stressors. It is inadequate for the EPA to skip this step and simply 

claim no harm to any potential community without notification. The EPA failed to issue a notice 

in Spanish.

Public notice participation The EPA failed to demonstrate that it notified participants in the State 

action(s) about this proposed permit. The EPA failed to demonstrate that it provided Notice to 

the appropriate elected officials. The EPA should reissue a Public Notice to the appropriate 

elected officials and members of the public who have expressed an interest in this project and 

other projects in the area. The public Notice fails to disclose any effect on air quality. A new 

notice should demonstrate the projects effects in relationship to the National Ambient Air 

Quality Standards or at least in gross pollutant weights. The Notice fails to alert the public of a 

reason to participate. 

The analysis is misleading because it does not disclose that the project intends to burn “urban 

wood” or post-consumer wood which would be more appropriately burned with a DLN Burner 

“In addition, there are 50,000 BDT of agricultural and urban wood

wastes available to SPI annually.” Application

DLN Burner 

With two or more DLN burners, the biomass combustion fuel would need to be pulverized and 

burned in suspension using wall-mounted burners. This presents a significant departure from 

SPI’s proposed boiler design where combustion occurs on a moving grate. DLN burners are 

designed to limit the amount of fuel-bound nitrogen that is converted to NOx during combustion, 

and are generally suited to boilers that burn wood waste containing a high percentage of resins, 

such as the waste from medium density fiberboard, plywood, or veneer operations. The emission 

rate with DLN burners is projected to be 0.35 lb/MMBtu.

The permit fails to require appropriate Ash bunker waste disposal. It does little good if the ash is 

collected and then left to blow away into the air or contaminate some other resource. 

EMX, SCR and Urea should be required.

Consideration of the McNeil facility are entirely speculative. If the project is to be excused from 

the BACT demonstrated at McNeil than additional analysis is required 

Although the McNeil Generating Station has demonstrated a lower NOx emission limit on a 

calendar quarterly basis, it has a short term NOx emission limit of 0.23 lb/MMBtu. Moreover, 
the possible economic incentives of the Class 1 Renewable Energy Credits in New England are 

difficult to quantify and not available to SPI- Anderson. This may allow SCR system to be more 

economically feasible for McNeil Generating Station and other proposed systems in the New 

England area than for SPI- Anderson in California.

EPA does not anticipate additional significant environmental or energy impacts from employing 

the SNCR or SCR technology. Both systems use ammonia as a reagent: anhydrous ammonia, 

aqueous ammonia, or urea mixed with water (which hydrolyzes in the hot exhaust to form 

ammonia). In the case of aqueous ammonia or urea mixed with water, additional fuel must be 

combusted to evaporate the water associated with the reagent. Moreover, energy is required to 

operate the injectors used by either technology to introduce the reagent into the exhaust. With 

either technology, the exhaust leaving the boiler stack will contain some small quantity of 

ammonia.

The PSD increment trigger date should have been when the original permit was issued.

“With respect to the PSD increment analysis for PM2.5, the applicable trigger date when the 

PM2.5 increments become effective under the Federal PSD program is October 20, 2011. The 

SPI- Anderson PSD permit application was determined to be administratively complete by EPA 

on October 4, 2010. However, EPA is requiring each source that receives its PSD permit after 

the trigger date, regardless of when the application was submitted, to provide a demonstration 

that the proposed emissions increase, along with other increment consuming emissions will not 

cause or contribute to a violation of the PM2.5 increments. Also the major source baseline, 

which precedes the trigger date is the date after which actual emissions increases associated with 

construction at any major stationary source consume PSD increment. That date is October 20, 

2010. With this PSD permit, SPI-Anderson would begin construction after this date. In general, 

for PM2.5, the minor source baseline date is the earliest date after the trigger date of a complete 

PSD permit application for a source with a proposed increase in emissions of PM2.5 that is 

significant. No source has triggered the minor source baseline date in the area at issue. Other 

than SPI- Anderson’s projected construction emissions, there have been no actual emissions 

changes of PM2.5 from any new or modified major stationary source on which construction 

commenced after October 20, 2010. Therefore, the only source to consume PM2.5 increment in 

the area is SPI- Anderson. The applicant considered only the allowable emissions increase from 

the SPI- Anderson project in the 24-hour PM2.5 increment analysis”33

The analysis must demonstrate the Nitrogen and other pollutant deposition on the adjacent 

Elderberry plants

SPI has confirmed that construction activities will not occur within 100 feet of the elderberry 

shrubs that are in the Pacific Gas and Electric power line Right of Way. The nearest construction

activity to the existing elderberry plants will be the erection of the electrical power poles at the 

existing electrical sub-station which are 137 feet away from the nearest elderberry shrub. 45 

Rob Simpson 27126 Grandview Avenue Hayward CA. 94542 Rob@redwoodrob.com