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REVISION TO THF STATE IMPLEMENTA'TION PLAN FOR THE SOUTH COAST AIR 

QUALITY MANAGEMENT DISTRICT, STATE OF CALIFORNIA: SULFUR OXIDES AND 

PARTICULATE MATTER OFFSET REQUIREMENTS FOR THE PROPOSED CPV 

SENTINEL POWER PLANT TO BE LOCATED IN DESERT HOT SPRINGS, CALIFORNIA, 

INCLUDING AB 13 18 OFFSET TRACKING SYSTEM 

PREAMBLE: 

PURPOSE OF SIP REVISION 

The purpose of this source-specific revision to the State Implementation Plan (SIP) for the South 

Coast Air Quality Management District (AQMD) is to implement California AB 13 18 (2009, 

V.M. Perez) (Stats. 2009, Ch. 285), including California Health and Safety Code Section 

40440.14. That section requires the Executive Officer of the AQMD to credit to the South Coast 

District's internal emission credit accounts and transfer to eligible electrical generating facilities 

emission credits in the full amounts needed to issue permits for eligible electrical generating 

facilities to meet requirements for sulfur oxides and particulate matter emissions. The proposed 

CPV Sentinel, LLC power plant has been found to be an eligible electrical generating facility 

under this section, and is the only known eligible facility. The proposed SIP revision will 

provide a mechanism for the transfer of credits to CPV Sentinel, and will establish the AB 13 18 

-- tracking system used to account for such credits. 

DESCRIPTION OF PROPOSED POWER PLANT 

CPV Sentinel, LLC has proposed to build an 850 megawatt (MW) natural gas-fired power plant, 

to be located at 62575 Power Line Road, Desert Hot Springs, California, 92440. The project has 

submitted an Application for Certification to the California Energy Commission (07-AFC-3) 

and has submitted a Title V Application for a Permit to Construct to the AQMD (Facility ID No. 

152707) The proposed plant has been found to be an eligible electrical generating facility under 

Health and Safety Code section 40440.14(d) because it is (1) subject to the permitting 

jurisdiction of the State Energy Resources Conservation and Development Commission (also 

referred to as California Energy Commission or CEC), (2) it has a purchase agreement, executed 

on or before December 3 1, 2008, to provide electricity to a public utility, as defined in Section 

216 of the Public Utilities Code, subject to regulation by the Public Utilities Commission, for use 

within the Los Angeles Basin Local Reliability Area, and (3) it is under the jurisdiction of the 

South Coast Air Quality Management District, but not within the South Coast Air Basin (it is 

proposed to be located in the Salton Sea Air Basin). In addition, the AQMD has found that the 

proposed CPV Sentinel project meets all the requirements of the applicable new source review 

rule and all other applicable district regulations that must be met under Section 1744.5 of Title 

20 of the California Code of Regulations, as required by Health and Safety Code Section 

- 40440.14(a). 
REASON FOR SIP REVISION 

California Health and Safety Code section 40440.14 in AB 13 18 requires the Executive Officer 

of the AQMD to credit to the AQMD's internal emission credit accounts and to transfer to 

eligible electrical generating facilities, which includes only the CPV Sentinel power plant, 

emission credits in the full amounts needed for particulate matter and sulfur oxides to issue 

permits to the proposed CPV Sentinel power plant. To implement AB 13 18, this SIP revision 

provides a federally-approved mechanism to transfer credits from the AQMD's internal accounts 

to offset the CPV Sentinel Energy Project proposed Power Plant because CPV Sentinel is not 

eligible for either Rule 1304 or the May 3,2002 version of Rule 1309.1 and AB 13 18 requires 

the transfer of the specified credits. 

ESTABLISHMENT OF AB13 18 TRACKING SYSTEM FOR CPV SENTIIVEL POWER 

PLANT 

AQMD has decided to establish a new tracking system for the CPV Sentinel Energy Project 

specific to AB 13 18 which consists of specific offsets credits that have been identified from 

reductions occurring from permitted equipment that permanently ceased operations in AQMD. 

The AQMD has not issued any ERCs for these specific emission reductions to the companies 

that operated the equipment as a result of the reductions. These Sox and PM10 offsets have been 

removed from the AQMD's internal offset accounts and have not been used by any other source, 

nor will they be used by any other projects in the future if they are used for the CPV Sentinel 

Energy Project. These offsets are also described in the documented entitled "CPV Sentinel 

Energy Project AB 13 18 Tracking System" attached hereto. 

The amounts of emission offsets contained in the AB 13 18 Tracking System are based on actual 

SOX and PMlO emissions reported to AQMD under AQMD's Annual Emissions Reporting 

Program. In addition, for each source of credit, the equipment has been shut down and the 

permits have been inactivated by AQMD. The emission reductions for SOX and PM 10 have 

occurred during calendar years 1999 through 2008. The offsets deposited in the AB 13 1 8 

Tracking System meet all the U.S. EPA's integrity criteria for qualifying as offsets, meaning 

they are all real, permanent, enforceable, quantifiable, and surplus. The AB 13 18 Tracking 

System is being submitted to U.S. EPA for approval. 

TEXT OF SIP REVISION - CPV Sentinel Energy Project AB 13 18 Tracking System 

The proposed text of the SIP revision is as follows: 

The Executive Officer of the South Coast Air Quality Management District shall transfer sulfur 

oxides and particulate emission credits from the CPV Sentinel Energy Project AB 13 18 Tracking 

System, attached hereto and incorporated by reference herein, to eligible electrical generating 

facilities pursuant to Health and Safety Code section 40440.14, as in effect January 1, 2010, (i.e. 

the CPV Sentinel Power Plant to be located in Desert Hot Springs, CA) in the full amounts 
needed to issue permits to construct and to meet requirements for sulfur oxides and particulate 

matter emissions. Notwithstanding District Rule 1303, this SIP revision provides a federally 

enforceable mechanism for transferring offsets from the AQMD's internal accounts to the CPV 

Sentinel Project. The Executive Officer shall complete the transfer of credits to an electrical 

generating facility pursuant to this provision upon the receipt of payment of the mitigation fees 

set forth in the south coast district's Rule 1309.1, as adopted on August 3, 2007, regardless of the 

subsequent repeal of those provisions. This section shall remain in effect only until January 1, 

2012, and sunsets as of that date. Such repeal does not affect the federal approvability of credits 

or the transfer of such credits that are transferred prior to the repeal. 

OFFSET EVALUATION FOR CPV SENTINEL PROJECT 

The offset evaluation for SOX and PMlO for the CPV Sentinel Project is included in the CPV 

Sentinel Energy Project AB 13 18 Tracking System as authorized by AB 13 1 8 and is being 

submitted to U.S. EPA for approval and inclusion into the SIP. The offset requirements for VOC 

and NOx are being met by compliance with existing SIP-approved AQMD rules and do not 

require any additional approvals from U.S. EPA. The Salton Sea Air Basin is not designated as 

Nonattainrnent for either CO or PM2.5 and therefore offsets are not required for these pollutants. 

".. CAA 5 1 1 O(1) ANALYSIS 

This SIP revision does not interfere with any applicable requirement concerning attainment or 

reasonable further progress or any other requirement of the Clean Air Act, as provided in CAA 

5 1 10(1), 42 U.S.C. 5 74 1 O(1). This SIP revision merely provides a mechanism for satisfying the 

offset requirements of CAA 5 173, 42 U.S.C. 5 7503, which fully satisfies that requirement. 

Even if the § 11 O(1) analysis included the air quality impacts of operation of the CPV Sentinel 

Energy Project, the accompanying "Air Quality Demonstration: SIP Revision for CPV Sentinel 

Energy Project" shows that operation of the plant does not violate 5 11 O(1).