### Gretel Smith
S TAFF C OUNSEL H ELPING H AND T OOLS

GRETEL

. SMITH 79@ 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

corpora tio n 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 request s 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 demonstr ate 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 w ho 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 re issued ; 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 Environment a l 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 Just ice evaluation to support the conclusion stated

.Air Quality Impacts

Air Quality Monitoring used t o Determi ne 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
bac kground ambi ent air quality must be done at or near the actual site in order to obtain accurat e data th at 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 offs ite facilities via truck. The AQIA fails to analyze the cumulative impact on GHG and other emissions the trucks contribute to the overal l emissions of the plant. The secondary environmental impact from transporta tion of the bio fuel and the removal of waste from the facility should be analyzed. Further, the AQIA does not analyze the cumulative i mpact of the secondary emissions from the kilns. The AQIA should analyze secondary emissions , BACT on the secondary emissions should be imposed, and t he 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 ac hieves 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 comp leted.

SCR v. SNCR B

ACT Analysis

Under t he 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. Additio nally, ammonia slip s vary from the types of ammonia utilized by the plant. The AQIA needs to inc lude a more thorough analysis with regards to the ammonia usage, and storage of the ammonia. Step 4 of t he BACT analysis comparing the SCR and SNCR fails to analyze co mparative costs of facilities. The analysis shoul d 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 tothe GHG emissions o f the plant. At minimum a BACT analysis should be done on the GHG

emissions from the use of the natural gas at t he 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 an alyze the use of a solar comp on e nt 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 comp on e nt.

Emissions Deposition Impacts

The AQIA does not fully analyze the nitrogen deposition impact of the surrounding area. The AQI A should analyze th e 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 full y analyze cumulative air quality impacts of secondary sources. The background ambient air quality is based upon data 55.5 miles from the proposed site whic h 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 matt er are incorporated by reference herein and enclosed with this letter

.

Sincerely,

Gretel Smith, Esq. Staff Counsel for Helping H a nd Tool s (619)822

- 6262
Gretel

. smith79@gmail.com

Enclosure cc: Rob Simpson, CEO Helping Hand ToolsRob 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;

Th e 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 thi s 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 a nd 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 “lower

polluting 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 ma y 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...S ee, 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 bas ed 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 fu els 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 a llocationof 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 fr om 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 sola r 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 t he 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 associat ed 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 produ ce 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 clo sed

- 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 t his 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 p ermit 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 faile d 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 a nd 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 permi t. 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 pr ojects 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 a re 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 present s 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 bunke r 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 sh ort 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 s ystems 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 Oct ober 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 d ate 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 an d 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@re dwoodrob.comRob 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;

Th e 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 thi s 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 a nd 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 “lower

polluting 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 ma y 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...S ee, 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 bas ed 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 fu els 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 a llocation of primary fuels would fundamentally redefine the proposed source, the options at Step 1 shouldinclude varying allocations of the two primary fuels if the proportional allocation of fuels has the

potential to affect the amount of GHGs emitted fr om 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 sola r 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 t he 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 associat ed 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 produ ce 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 clo sed

- 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 t his 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 p ermit 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 faile d 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 a nd 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 permi t. 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 pr ojects 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 a re 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 present s 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 bunke r 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 sh ort 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 s ystems 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 Oct ober 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 d ate 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 an d 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@re dwoodrob.com