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I Have Multiple Facilities or Sources

-How Do I Determine What to Report?

    Who and What needs to report is based on
  1. the physical continuity (or lack thereof) of the facility
  2. Physical Continuity: Facility is any property, plant, building, structure, stationary equipment or grouping of stationary equipment that is contiguous, or joined in adjacent plots of land, or only separated by a road, that is under the common operational control of the operator.

  3. operational control
  4. Operational Control: Operational Control means authority to implement operational policies in the facility. If two entities share operational control, entity named on the permit is the operator and is considered to have operational control for the purposes of reporting.

  5. the named operator
  6. Operator: Operator means entity having operational control. For electricity reporters, operator means either the marketer, retail provider, or facility operator. When in doubt, the Operator is whatever entity is named in the facility’s permit with the local AQMD.

    -Need all three to determine the reporting facility – physical continuity, operator, and operational control over the entire facility.

Example 1: Toyota owns three manufacturing plants in the State. They are separated from each other by at least 50 miles each. Toyota is the named Owner on the permits for the plants with their local AQMD’s, and Toyota maintains “Operational Control” over all three facilities. For reporting, do all three facilities count their emissions together for the purposes of determining their reporting threshold?

No. Each facility is physically separate from one another and is evaluated separately to determine if they fall within the 25,000 metric tonne threshold to report.

 

Example 2: A Hospital has a cogeneration system on-site with a nameplate capacity of at least 1MW and emissions associated with electricity production above 2,500 metric tonnes of CO2. The generator is owned by both the Hospital and an outside Generator company. The Generator Company is named on the permit with the local AQMD. Who reports?

Generator Company named on the permit. Although the Hospital is exempt, the Generator Company named on the permit is not, and both the Hospital and the Generator Company share operational control of the generator.

 

Example 3: Refinery with a cogeneration facility on-site. One operator named on the permit with operational control over both the refinery and cogeneration facility. Cogeneration facility has a nameplate capacity of at least 1MW and emissions associated with electricity production above 2,500 metric tonnes of CO2. Refinery and cogeneration facility, when added together, come under the 25,000 metric ton limit. Report?

Cogeneration facility must report. Refinery does not have to report. Cogeneration facility is a separate source, even if it is physically within the confines of the refinery, and it meets the minimum reporting thresholds of the statute for cogeneration facilities.