Spokane Regional Clean Air Agency
Title V Program Review
(2nd Round)
EPA Region 10
September 28, 2018
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Table of Contents
I. Introduction 3
SRCAA's Title V Program 3
Program Review Objective and Overview 3
Program Review Report Structure 5
II. Follow-up to 2006 Program Review 6
Section A. Title V Permit Preparation and Content 6
Section B. General Permits 7
Section C. Monitoring 8
Section D. Public Participation and Affected State Review 11
Section E. Permit Issuance / Revision / Renewal 11
Section F. Compliance 12
Section G. Resources and Internal Management Support 13
Section I. Document Review (Rules/Forms/Guidance) 14
III. Additional Review 16
New Concerns (and Suggestions) 16
IV. Summary of Concerns and Recommendations 18
Concerns 18
Recommendations 18
Attachments
1 Program Review Kickoff Letter and Information Request, July 9, 2018
2 Program Review Information Request Response, July 23, 2018
3 Title V Operating Permit System Reported Data
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I. Introduction
This report documents the second review of the Spokane Regional Clean Air Agency's1
(SRCAA's) Title V permitting program. The first Title V program review for SRCAA was
completed in August 2006.
SRCAA's Title V Program
The Spokane Regional Clean Air Agency is a local air pollution control agency with jurisdiction
throughout Spokane County in the state of Washington. SRCAA implements the state of
Washington operating permit regulations found in Washington Administrative Code 173-401,
but has their own fee rules. The Environmental Protection Agency Region 102 granted SRCAA
full approval of its title V program, effective September 12, 2001. 66 FR 42439 (August 13,
2001). A revision to Washington's Title V rules was approved, effective on January 2, 2003. 67
FR 71479 (Dec 2, 2003). We have not approved any revisions to Washington's title V program
since 2003. SRCAA has revised their fee rules three times since 2003; these revisions did not
require EPA approval.
SRCAA currently issues Title V permits to approximately 8 sources. There are two permit
writers that are responsible for writing Title V permits as well as processing construction
permits. A third permit writer only works on construction permits. There are other staff that
provide enforcement and accounting support to the Title V program.
Program Review Objective and Overview
The EPA initiated Title V program reviews in response to recommendations in a 2002 Office of
Inspector General audit. The objective of broader program reviews (as opposed to individual
permit reviews) is to identify good practices that other agencies can learn from, document areas
needing improvement and learn how the EPA can help improve state and local Title V programs
and expedite permitting.
The EPA set an aggressive initial national goal of reviewing all state and local Title V programs
with 10 or more Title V sources. SRCAA was one of ten Title V programs in Region 10
reviewed between 2004 and 2007. Here is the list of agencies in Region 10 reviewed in the first
round along with the final report date and an approximate number of Title V sources they
regulated when reviewed:
Permitting Authority (first round)
Report
Date
Permits
Idaho Department of Environmental Quality
January
2004
59
Oregon Department of Environmental Quality
June
2006
111
Lane Regional Air Protection Agency (OR)
June
2006
19
Spokane Regional Clean Air Agency (WA)
August
2006
10
Puget Sound Clean Air Agency (WA)
September
2006
35
Washington Department of Ecology
September
2006
27
Northwest Clean Air Agency (WA)
September
2006
21
Alaska Department of Environmental Conservation
September
2006
158
Olympic Regional Clean Air Agency (WA)
September
2007
15
Southwest Clean Air Agency (WA)
September
2007
12
1 Spokane Regional Clean Air Agency was named Spokane County Air Pollution Control Authority (SCAPCA)
during the 2006 Title V program review.
2 In this report, the term "EPA" refers to the United States Environmental Protection Agency as a nationwide
agency. The term "Region 10" and the first-person plural (we/us/our) refer to EPA Region 10.
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In response to a follow-up review by the Office of Inspector General, the EPA also committed to
repeat the reviews of all Title V programs with 20 or more Title V sources every four years
beginning in 2007. The original, second-round commitment covered each of the four state
programs in Region 10 (Alaska, Idaho, Oregon and Washington) as well as two local agencies in
Washington (Puget Sound Clean Air Agency and Northwest Clean Air Agency). In September
2016, we fulfilled that commitment and decided to continue second-round reviews for the
remaining agencies that were reviewed in the first round, but not yet reviewed for a second time.
Below is the list of agencies reviewed to date in the second round along with the final report
date. All of the program review reports can be found on Region 10's air permitting website.3
Permitting Authority (second round) Report Date
Idaho Department of Environmental Quality September 2007
Puget Sound Clean Air Agency (WA) September 2008
Northwest Clean Air Agency (WA) September 2013
Washington Department of Ecology September 2014
Alaska Department of Environmental Conservation September 2015
Oregon Department of Environmental Quality September 2016
Lane Regional Air Protection Agency (OR) September 2017
In the first title V program review, we covered all major elements of a title V program. In the
second round of program reviews, we focused on issues specific to each permitting authority's
implementation of its permitting program. Of particular interest is how each authority has
addressed the concerns identified in the first review. We also considered permit issuance
progress, resources, compliance assurance monitoring (which is required to be added during
permit renewal for most sources) and how programs have integrated new requirements and rules
into their permits and program.
To prepare for this review, Region 10 sent a letter in June 2018 requesting specific information
from SRCAA (Attachment 1). Region 10 reviewed SRCAA's emailed response (compiled as
Attachment 2) which included, as requested, a staff list, financial records, and an update
regarding each of the concerns raised in 2006.
Region 10 also reviewed past permit issuance data SRCAA reported to the Title V Operating
Permits System (Attachment 3) and a selection of recently-issued permits. Permits issued more
recently were intentionally selected for review to provide a more accurate depiction of how
SRCAA's permits have changed since the first program review. The permits reviewed include:
Permit No. Company Name (Location) Date Issued
AOP-16 Spokane Northside Landfill 07/17/2017
AOP-15 Melcher Manufacturing Company 01/29/2018
AOP-11 Kaiser Aluminum 10/30/2017
While on site at SRCAA's office on August 7-8, 2018, Region 10 staff interviewed permit
writing staff, enforcement staff and the agency director. The purpose of the interviews was to
clarify and discuss what was learned from the review of their permits and other information.
Region 10 staff and SRCAA staff discussed permit issuance progress, program resources (and
the fee program), general program implementation topics, and specific issues identified during
the previous review of SRCAA's program including compliance assurance monitoring.
3 https://www.epa.gov/caa-permitting/permit-program-reviews-epa-region-10
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Program Review Report Structure
This program review report is presented in four main sections:
I. Introduction
II. Follow-up to 2006 Program Review
III. Additional Review
IV. Summary of Concerns and Recommendations
Section I presents some background regarding SRCAA's Title V program as well as an overview
of Region 10's program review plan. Section II presents Region 10's evaluation of SRCAA's
progress in resolving concerns identified in the 2006 program review. Section III presents
additional observations from Region 10's review of SRCAA's individual permits including the
application of compliance assurance monitoring. Finally, Section IV summarizes Region 10's
second-round concerns and presents Region 10's recommendations for resolving any outstanding
issues.
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II. Follow-up to 2006 Program Review
In the initial Title V program review, finalized in August 2006, Region 10 provided observations
delineated into nine separate topic areas labeled A through I. In each section, Region 10
identified good practices, concerns and other observations and asked SRCAA to respond to the
concerns identified. In February 2007, SRCAA responded to Region 10 addressing the concerns
identified by Region 10. SRCAA further addressed two outstanding issues in July 2007.
SRCAA's 2007 responses were included in SRCAA's update in Attachment 2.
This section of the second-round program review report presents Region 10's evaluation of the
progress SRCAA has made in addressing the concerns identified in the initial program review.
Each of Region 10's original concerns is listed below, followed by SRCAA's 2007 responses,
SRCAA's 2018 update, and, finally, Region 10's second-round (Round 2) evaluation.
Section A. Title V Permit Preparation and Content
A-l 2006 EPA Concern: The table format used by SRCAA, and other permitting authorities
in Washington, can lead to difficulties for permit engineers. Some permit engineers tend
to abbreviate necessary wording of rules and requirements in order to fit lengthy text into
the narrow columns, which can lead to unclear or incomplete requirements. Formats that
do not limit the space for writing a requirement help to ensure the requirement is written
with the necessary details and formatting to make the requirement clear. Often,
substantial portions of pages are blank because all of the text is in a single column, which
unnecessarily lengthens the permit without adding value. In Table 1 of the permits, due to
the need to cite multiple regulations in column two, the other columns are under-utilized.
While it would likely take a considerable effort to change all of the permits to a text
format (see permits issued by Oregon or Idaho), SRCAA should consider the benefits of
making the changes during permit renewals.
2007 SRCAA Response: SRCAA would prefer to continue using the table format in our
Title V permits for several reasons. First, our sources like the table format for ease of
reading and because it is what they are accustomed to seeing. Second, as stated in the
report, other permitting authorities in Washington use the table format, which leads to
more state-wide consistency and uniformity in permits written by local authorities in
Washington. Lastly, SRCAA's format includes all of the required elements for a Title V
permit.
2018 SRCAA Update: SRCAA is still using table format in permits.
Round 2 Evaluation: Region 10 has, on several occasions, shared its opinion regarding
formats that seem to work better, but EPA does not mandate a particular permit format.
As long as SRCAA's permits comply with Title V, we will no longer consider this a
concern that warrants follow-up.
A-2 2006 EPA Concern: SRCAA's statements of basis should contain a discussion of the
facility's compliance history. In a December 20, 2001, letter from EPA Region 5 to the
Ohio EPA, EPA provided guidelines on the content of an adequate statement of basis that
meets the requirements of 40 C.F.R. § 70.7(a)(5). That letter states, among other things,
that the statement of basis should include factual information that is important for the
public to be aware of including the compliance history of the source such as inspections,
any violations noted, a listing of consent decrees into which the permittee has entered and
corrective action(s) taken to address noncompliance.
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2007 SRCAA Response: In the future, SRCAA will add a discussion of the facility's
compliance history to the statements of basis. SRCAA will implement action in all new
and renewal permits drafted from this point forward.
2018 SRCAA Update: SRCAA includes a section on facility's compliance history in
statements of basis.
Round 2 Evaluation: SRCAA's statements of basis consistently include a compliance
history. This issue has been resolved.
A-3 2006 EPA Concern: SRCAA's statements of basis should contain a discussion of facility
permitting history. This type of discussion is important to allow the reader to analyze
what requirements might potentially apply to the source and to serve as a record of
facility changes for determining applicability for minor new source review (NSR) and
prevention of significant deterioration (PSD) purposes.
2007 SRCAA Response: In the future, SRCAA will add a discussion of facility
permitting history to the statements of basis. SRCAA will implement action in all new
and renewal permits drafted from this point forward.
2018 SRCAA Update: SRCAA includes a section on facility's permitting history in
statements of basis.
Round 2 Evaluation: SRCAA's statements of basis consistently include a permitting
history. This issue has been resolved.
A-4 2006 EPA Concern: It would be helpful if the statement of basis included a discussion
regarding whether a facility is a major source of hazardous air pollutants.
2007 SRCAA Response: In the future, SRCAA will add a discussion regarding whether
a facility is a major source of hazardous air pollutants to statements of basis. SRCAA will
implement action in all new and renewal permits drafted from this point forward.
2018 SRCAA Update: SRCAA includes a discussion of whether the facility is a major
source of HAPs in the statements of basis.
Round 2 Evaluation: SRCAA's statements of basis consistently either discuss whether
the source is major for HAPs or implies it by explaining MACT or area source NESHAP
applicability. However, none of the statements of basis included a potential to emit
summary that would support the discussion. That goes for other non-HAP regulated air
pollutants as well. In fact, potential to emit emission inventories were generally not
included with the statements of basis. Region 10 recommends including in the statements
of basis a table with the potential to emit of all regulated pollutants including HAPs and
optionally appending to the statements of basis a potential to emit emission inventory.
This will provide necessary information to support applicability claims and can be useful
for other purposes such as assisting with compliance assurance monitoring applicability
and source size. For additional guidance on the content of statements of basis, see EPA's
April 30, 2014 guidance document entitled, "Implementation Guidance on Annual
Compliance Certification Reporting and Statement of Basis Requirements for Title V
Operating Permits."
Section B. General Permits
SRCAA has not issued any general Title V permits, so this topic was not covered during the
program review.
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Section C. Monitoring
C-l 2006 EPA Concern: SRCAA's permits contain general testing requirements that include
the ability to have alternative test methods approved by SRCAA. The permit cannot
authorize approval of an alternative test method outside of the permit revision process. In
addition, SRCAA cannot approve an alternative to the test method that is approved as
part of the state implementation plan (SIP). See 40 CFR 51.212.
2007 SRCAA Response: In the future, for federal testing requirements, SRCAA will
take "alternate test methods approved by SRCAA" out of the permits. However, for non-
federal testing requirements, permits will continue to allow for "alternate test methods
approved by SRCAA," especially if this provision is contained in the underlying
requirement (e.g., NOC approval order). SRCAA will implement action in all new and
renewal permits drafted from this point forward. (July 2007 follow-up) In the future,
SRCAA will not include a provision that allows for alternative test methods.
2018 SRCAA Update: SRCAA does not include any alternate test methods for federal
testing requirements.
Round 2 Evaluation: It is clear that SRCAA staff understand the limits of their authority
regarding the approval of alternative test methods and have attempted to avoid language
that can be misinterpreted. Unclear permit language, when implemented by staff that
understand their authority, does not mean that incorrect decisions about alternative test
methods have been made. Still, the alternative test method language in their permits,
particularly the general test method language, can be improved to clarify who can
approve each type of alternative method for each type of applicable requirement. We
recommend SRCAA revise their permit language where it can be misinterpreted. During
the onsite interviews, Region 10 also shared an approach for Title V permit approvals of
alternative test methods for requirements originally established in construction permits,
without having to reopen the original construction permit.
C-2 2006 EPA Concern: Although SRCAA requires facilities to develop a monitoring plan
detailing how inspections will be performed and how records will be kept, the monitoring
plan is not incorporated into the permit. As a result, much of the compliance assurance
provisions for various emission units are essentially "off-permit." Furthermore, there are
no provisions for SRCAA approval or oversight of the monitoring plan. There are two
options for addressing this issue. First, the entire plan could be attached to the permit and
incorporated by reference into the permit. Revisions to the plan could then be
incorporated into the permit through the part 70 permit revision procedures. Second,
SRCAA could pull out from the plan and include in the permit the key provisions for
assuring compliance with the emission limits, such as the pressure drop range for a
scrubber.
2007 SRCAA Response: In the future, SRCAA will pull key provisions for assuring
compliance with the emission limits from monitoring plans, such as the pressure drop
range for a scrubber, and include them in the permit. SRCAA already does this as a
general practice. However, when an operation and maintenance plan includes best
management practices and other procedural requirements and does not include
measurable parameters or other key provisions that assure compliance with an emission
limit, SRCAA would prefer to keep the plan "off-permit." SRCAA would also prefer to
keep lengthy operation plans which are revised regularly, such as the one developed for
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our Waste-to-Energy facility, off-permit. Many of the revisions made to these plans
would not have a direct correlation with any emission limit for the facility. If SRCAA
were required to revise an air operating permit for each change to an operation plan, this
would cause a significant workload increase with little air quality benefit. SRCAA will
implement action in all new and renewal permits drafted from this point forward.
2018 SRCAA Update: SRCAA pulls out key provisions, when possible, and includes
them in the permit for assuring compliance with emission limits. However, for facilities
with long and/or complicated O&M plans which are revised routinely, SRCAA still
keeps the plan "off-permit."
Round 2 Evaluation: SRCAA staff clearly understands the benefit of including in the
permit those key provisions of monitoring and maintenance plans that are important for
assuring compliance. Our review did not identify any examples where additional
monitoring or maintenance provisions were clearly necessary to assure compliance. We
will no longer consider this a concern that warrants follow-up.
C-3 2006 EPA Concern: Some of SRCAA's permits allow for visible emission observations
to monitor compliance with a particulate limit other than opacity. When this approach is
used, and any threshold for action other than "any visible emissions" is relied upon, a
relationship between the emission limit and opacity should be justified through emission
testing or other reliable information. Likewise, available emission testing results should
have been used for this purpose. In the case where "any visible emissions" is used, the
general concept that something will be visible before a compliance problem exists is
generally reasonable justification.
2007 SRCAA Response: In the future, SRCAA will strive to establish a relationship
between a particulate limit and opacity through emission testing or other reliable
information, when opacity is used to monitor compliance with a particulate limit.
However, this approach will only be used when opacity levels higher than 0% are used to
demonstrate compliance with a particulate limit. SRCAA will continue to use the "no
visible emissions" (a.k.a., "smoke / no smoke") concept as monitoring for particulate
emission standards, without an established relationship between a particulate limit and
opacity, because we concur that something will be visible before a compliance problem
exists. SRCAA will implement action in all new and renewal permits drafted from this
point forward.
2018 SRCAA Update: SRCAA strives to establish a relationship between particulate
limit and opacity, when data is available. SRCAA still uses the "no visible emissions"
concept as monitoring for particulate emission standards without an established
relationship
Round 2 Evaluation: Like many permitting authorities, SRCAA commonly uses opacity
monitoring to assure compliance with particulate matter emission limits - see monitoring
requirement 1M in most permits. The monitoring procedure requires emission testing if
observed visible emissions cannot be remedied. SRCAA staff indicated that nearly all
their sources routinely operate with zero opacity emissions, and the requirement to test
when opacity cannot be returned to zero generally doesn't happen. If that was not the
case, Region 10 would recommend requiring opacity measurements simultaneous with
the particulate testing to establish a relationship between opacity and particulate
emissions to monitor compliance with the particulate limit. If visible emissions later
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exceed those observed during particulate testing, additional testing may be necessary.
The only other instance where SRCAA relies on opacity to confirm compliance with a
particulate matter limit was supported with a thorough emission testing study. We no
longer consider this a concern that warrants follow-up.
C-4 2006 EPA Concern: The frequency of source testing should generally depend on how
close actual emissions are to the standard. More rigorous monitoring, recordkeeping and
reporting requirements should generally be required when source tests indicate that actual
emissions are very close to emission limits. Under such circumstances, source testing
once every five years does not generally provide reasonable assurance of compliance. In
addition, even in the case of more frequent source testing, the permit should also
generally require monitoring of the same operational parameters that were monitored
during the most recent compliant source test to ensure that the equipment is operating in
the same manner as it did during the compliant source test. In a peaking plant permit we
reviewed, the monitoring, recordkeeping and reporting requirements do not appear
adequate to assure compliance with the emission limits, as actual emissions of certain
pollutants appear to be very close to the corresponding emission limits.
2007 SRCAA Response: SRCAA does base the frequency of source testing on how close
actual emissions are to the standard. However, SRCAA also bases the frequency of
source testing on how often the equipment operates. For the Avista peaking plant, which
was referenced in the draft report, this equipment only runs every ~ 3 years, other than
for testing purposes. SRCAA does not think it is appropriate to require the equipment to
operate solely for the purpose of testing the emissions. The peaking plant is required to be
tested every 1,700 hours of operation (which would be triggered every three months, if
the equipment was to run continuously) or every 5 years, whichever occurs first. SRCAA
believes that this approach is justifiable and adequately assures compliance with the
emission limits, especially given in the frequency of operation for the equipment.
SRCAA also does require monitoring of the operational parameters that were monitored
during the source test to ensure that the equipment is operating in the same manner as it
did during the test. In the case of the Avista peaking plant, the only pertinent parameter to
monitor (since these are uncontrolled turbines, except for the oxidation catalysts) is the
oxidation catalyst pressure drop. This parameter is required to be kept within the
acceptable range specified in the O&M plan. SRCAA did ensure that the acceptable
range in the O&M plan was in-line with the pressure drop monitored during the source
test. However, this fact was not well documented in the statement of basis. In the future,
SRCAA will more clearly document the relationships between required monitoring and
operational parameters that are monitored during source tests in the statements of basis.
SRCAA will implement action in all new and renewal permits drafted from this point
forward.
2018 SRCAA Update: SRCAA bases the frequency of source testing on how close the
actual emissions are to the standard and how often the equipment operates.
Round 2 Evaluation: SRCAA explained in one statement of basis how the required test
frequency was based on how close past test results were to the applicable standards. For
other permits, it wasn't obvious whether SRCAA considered how close past test results
were to the standards. Where past data exists and future testing is being required, SRCAA
should not only consider this when setting test frequencies, but should document the data
and decision in the statement of basis.
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C-5 2006 EPA Concern: The monitoring, recordkeeping and reporting requirements in
permits are numbered such that it is very difficult to cite a particular section of a
requirement. In the case of correspondence or enforcement action, it is necessary to cite a
more general requirement (e.g. 1M, 2M etc.) and then describe the specific action of
interest. It is probably useful to establish a hierarchical numbering structure within each
condition.
2007 SRCAA Response: SRCAA will attempt to separate out various sections of
monitoring, recordkeeping, and reporting requirements, when appropriate and useful.
SRCAA will implement action in all new and renewal permits drafted from this point
forward.
2018 SRCAA Update: SRCAA attempts to separate out various sections of MRRR,
when it is appropriate and/or possible.
Round 2 Evaluation: It appears that SRCAA has addressed this issue. We no longer
consider this a concern that warrants follow-up.
Section D. Public Participation and Affected State Review
D-l 2006 EPA Concern: Like many of the permitting authorities across the country, SRCAA
provides the permittee with a pre-draft permit for review and comment before the draft
permit goes out for public comment. Soliciting the permittee's input on the factual
aspects of the permit can help to reduce errors in the permit and help educate the
permittee on its obligations under the permit. Working with the permittee on developing
the substantive permit requirements through multiple permit iterations can, however,
create the impression that the permit issuance process is not an open process. SRCAA
should carefully balance these interests as it works with permittees during the
development and issuance of Title V permits.
2007 SRCAA Response: During the public comment period on the draft permit, the
public is welcome to look at SRCAA's Air Operating Permit review files, which contains
all "pre-draft" permit work and communications between the permittee and SRCAA.
During the public comment period, all comments received, including any comments on
"pre-draft" permit work, is considered and addressed by SRCAA.
2018 SRCAA Update: SRCAA's practice remains the same on "pre-draft" work.
Round 2 Evaluation: This is generally not an issue when the agency documents the basis
for all of the requirements in the permit and assures that all comments received during the
public comment period are documented and addressed before the permit is issued.
SRCAA understand and implements their program this way. As long as SRCAA
continues to make the entire record available to the public during the public review
process, Region 10 is satisfied with SRCAA's approach for ensuring transparency. We no
longer consider this a concern that warrants follow-up.
Section E. Permit Issuance / Revision / Renewal
E-l 2006 EPA Concern: Permits for three of the four renewal applications received by
SRCAA were issued late, due to resource constraints in prioritizing issuance of the initial
permits. SRCAA feels that with all of the initial permits issued, future renewal permits
will be issued on time.
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2007 SRCAA Response: SRCAA attempts to issue all permits in a timely fashion.
However, there are occasions when resource constraints and factors that are out of
SRCAA's control may cause a renewal permit to be issued after the initial permit
expiration date. However, the facility would not be without a permit, since the initial
permit remains in effect after the initial permit expires, provided that the applicant has
submitted a timely renewal application to SRCAA.
2018 SRCAA Update: SRCAA's practice remains the same on renewal applications.
Resource constraints and other factors are still present and create backlogs for renewal
permits.
Round 2 Evaluation: SRCAA renewed three of their eight permits, or 37%, within the
last year, all after being administratively extended. Based on SRCAA's TOPS report for
the first half of 2018, only one permit was administratively extended past its original
expiration date as of July 1, 2018. According to SRCAA staff, three more permits will
become administratively extended permits before the end of calendar year 2018 creating
a significant backlog (50% of their Title V sources). SRCAA staff explained that an
increased construction permit workload and several complicated permits prevented them
from getting to the operating permits with expiration dates in 2018. It can be challenging
when several permits have expiration dates in the same general time period. To manage
that in the future, SRCAA should consider requesting some renewal applications earlier
than normal (to begin work earlier) or staggering issued permit expiration dates,
effectively spreading out the workload. We would like to see SRCAA's plan for tackling
the new backlog of administratively extended permits.
Section F. Compliance
F-l 2006 EPA Concern: Like many permitting authorities, SRCAA requires corrective
actions when certain monitored parameters are outside of the acceptable range. This is a
practical approach for assuring potential operational problems are addressed promptly.
When using this approach, SRCAA should clarify when a deviation occurs (when the unit
is outside the range or if corrective action is not taken), such that the appropriate records
are created and reported. Furthermore, SRCAA should add recordkeeping so each event
of operation outside the acceptable range is documented, even if it is not a deviation.
2007 SRCAA Response: In the future, SRCAA will clarify when a deviation occurs and
add recordkeeping so that each event of operation outside of an acceptable range is
documented. SRCAA will implement action in all new and renewal permits drafted from
this point forward.
2018 SRCAA Update: SRCAA attempts to clarify when a deviation occurs when
monitored parameters are outside of acceptable ranges.
Round 2 Evaluation: All three permits reviewed had some monitoring, recordkeeping or
reporting requirements for which deviation was not specifically defined. This lack of a
definition of deviation for each and every requirement may not be causing an
implementation problem (if the source and SRCAA agree what constitutes a deviation);
however, we believe that including the definition will help to assure sources know when
they should be reporting deviations. This can lead to better compliance and easier
enforcement.
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Section G. Resources and Internal Management Support
G-l 2006 EPA Concern: On-site interviews indicated that there may be confusion related to
allocation of permitting staff time (labor cost) to Title V and non-Title V budgets.
Activities associated with new source review (NSR) permit preparation are not Title V
fundable activities, even if the project is at a Title V source. Title V permit revisions to
accommodate NSR permit terms, and agency activities related to implementation of NSR
requirements contained in Title V permits are examples of activities that may be billed to
Title V. However, establishing or revising site-specific NSR permit terms may not be
billed to Title V. SRCAA permitting and accounting staff should examine this aspect of
their internal billing system and change it as needed.
2007 SRCAA Response: This issue has been addressed with SRCAA's recently revised
Title V fee regulations. See SRCAA Regulation I, Section 10.06 for the revised fee
regulation. (July 2007 follow-up) Currently, SRCAA does track the time and costs
associated with the Notice of Construction (NSR) program for the Title V sources. These
costs are paid by the Title V sources as part of their annual fee under the SRCAA Time
Fee. Therefore, it is not entirely true to state that funds collected under Title V are used to
develop NSR permits, since the sources do pay for the time associated with the NSR
permit. However, in order to make the NSR fees completely separate from the Title V
monies, SRCAA will amend our regulations to stipulate that the NSR fee schedule that
currently only applies to non-Title V sources will apply to all sources (including Title V
sources). Due to current Title V workloads (5 renewal applications currently in process)
and the resources necessary to perform a regulation revision, SRCAA will not be able to
initiate the regulation revision until 1st Quarter 2008. We trust EPA concurs that Title V
permitting work which directly impacts air quality should take precedence over
administrative issues like regulation amendments.
2018 SRCAA Update: Already addressed. The NSR fees were separated from the Title
V fees / monies through the fee revision completed by SRCAA in 2008.
Round 2 Evaluation: SRCAA understands and correctly implements this aspect of the
Title V fee program. SRCAA staff were aware of EPA's latest guidance memorandum
for managing fees, Program and Fee Evaluation Strategy and Guidance for 40 CFR Part
70, March 27, 2018. We no longer consider this a concern that warrants follow-up.
G-2 2006 EPA Concern: On-site interviews also indicated that there may be confusion
related to allocation of Title V penalties received by SRCAA. Penalties cannot be
attributed as Title V revenues and used to fund Title V activities. SRCAA permitting and
accounting staff should examine this aspect of their revenue and expenditure accounting
system and change it as needed.
2007 SRCAA Response: SRCAA has never used Title V penalties as Title V revenues
and will not do so in the future.
2018 SRCAA Update: Never has been an issue.
Round 2 Evaluation: SRCAA staff understand and correctly implements this aspect of
the Title V fee program. We no longer consider this a concern that warrants follow-up.
G-3 2006 EPA Concern: It appears that SCAPCA's Title V permit engineer has had limited
access to Title V training. Because of the limited demand in the geographical area, it is
very unlikely that training opportunities will occur in the Spokane, Washington, area.
SRCAA Title V Program Review - 2018
Page 13
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Resources must be available for staff to travel to proximate population centers such as
Seattle, Portland and Denver to access the latest and complete Title V and related
training.
2007 SRCAA Response: SCAPCA is committed to providing access to pertinent training
for all Title V staff. However, we have not seen many Title V training opportunities in
recent years in any proximate population centers. We will watch for future training
offered.
2018 SRCAA Update: SRCAA has offered Title V training to all appropriate staff. Both
permit engineers and the inspector attended EPA's most recent Title V workshop.
Round 2 Evaluation: SRCAA's permit writers are very experienced, requiring little
ongoing training. SRCAA staff rely on Westar for technical training and have been active
participants in the periodic Title V workshops held in Region 10, often leading the Permit
Writing 101 part of the workshop, wherein permit writers new to the program get
training. We no longer consider this a concern that warrants follow-up.
G-4 2006 EPA Concern: SCAPCA's Title V costs have exceeded revenues for a number of
years. At the time of EPA's visit to SCAPCA's offices, the program had amassed a
$77,000 deficit, which has been subsidized by local assessment money (from cities and
local governments - this is not grant money or Title V money). As EPA advised
SCAPCA in a letter dated August 15, 2002, failure to collect sufficient fees to support a
Title V program is a program deficiency that is grounds for withdrawal of SCAPCA's
Title V program. EPA's expectation is that SCAPCA revise its fee structure expeditiously
so that its Title V program is self-funding.
2007 SRCAA Response: This issue has been addressed by SCAPCA s proposed revised
fee regulations. In the revised fee regulation, all future Title V costs will be recovered
and past program deficit will be recovered over the next 10 year period.
2018 SRCAA Update: Already been addressed. No deficit to Title V program.
Round 2 Evaluation: SRCAA has resolved this issue and currently employs a budget
balancing system that assures potential shortfalls are identified and balanced with
subsequent collections. SRCAA's budget has been balanced consistently over the past
few years. We no longer consider this a concern that warrants follow-up.
Section I. Document Review (Rules/Forms/Guidance)
1-1 2006 EPA Concern: SCAPCA updates their rules periodically to adjust their fee rates.
EPA should be apprised of rule revisions. All rule revisions should be routinely submitted
for EPA review and approval, even the routine fee adjustments.
2007 SRCAA Response: SCAPCA will send rule revisions that are directly contained in
the SIP to EPA for review and approval. However, we are not aware of any requirement
to send rules, such as routine fee adjustments, to EPA for review and approval.
2018 SRCAA Update: Three rules revisions to Title V fees have been done since 2003.
Round 2 Evaluation: Title V rule changes that most likely warrant submittal and EPA
approval are only done by the Washington Department of Ecology. We prefer SRCAA
simply keep us apprised of fee changes. If we think a fee change requires submittal and
approval, we will notify SRCAA.
SRCAA Title V Program Review - 2018
Page 14
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1-2 2006 EPA Concern: On Form A-l, the questions in items 10 and 11 imply that a
permittee has a choice regarding whether such changes should be integrated into the
permit. A renewal permit should incorporate all off-permit changes made during the prior
permit term rather than continue to keep them off-permit.
2007 SRCAA Response: SCAPCA will change this item in our AOP renewal application
to ensure that all off-permit changes made during the prior permit term will be
incorporated into the renewal permit. SCAPCA will implement action in all renewal
applications sent out from this point forward.
2018 SRCAA Update: Change made to AOP renewal application.
Round 2 Evaluation: We no longer consider this a concern that warrants follow-up.
1-3 2006 EPA Concern: Form A-l (item 22) and the instructions for the form omit the
important qualification that ambient air quality data and air emissions data are not
entitled to confidential treatment. These documents should also include the qualification
that the information relate to "the production or process" unique to the applicant. It would
be helpful to cite to state law on confidentiality (RCW 70.94.205).
2007 SRCAA Response: SCAPCA will revise the AOP renewal application to cite the
state law on confidentiality and clarify that ambient air quality data and air emissions data
are not entitled to confidential treatment. SCAPCA has always ensured that any
information claimed confidential by an applicant meets the state law on confidentiality
(RCW 70.94.205) and does not include ambient air quality data and/or air emissions data.
SCAPCA will implement action in all renewal applications sent out from this point
forward.
2018 SRCAA Update: Changes made to AOP renewal application.
Round 2 Evaluation: We no longer consider this a concern that warrants follow-up.
1-4 2006 EPA Concern: In the instructions to Form A-l (item 22), some aspects of claiming
information as confidential under 40 CFR Part 2 are summarized. It would seem more
appropriate for SCAPCA's form to focus on the requirements for claiming information as
confidential under State law (RCW 70.94.205), rather than federal law, since it is state
law that will govern in the first instance (until the permittee is directed to provide the
information directly to EPA). In addition, EPA prefers that SCAPCA simply reference
federal law and not summarize it.
2007 SRCAA Response: SCAPCA will revise the instructions to Form A-l in the AOP
renewal application to refer to the state confidentiality law, rather than the federal law.
SCAPCA will implement action in all renewal applications sent out from this point
forward.
2018 SRCAA Update: Changes made to AOP renewal application.
Round 2 Evaluation: We no longer consider this a concern that warrants follow-up.
SRCAA Title V Program Review - 2018
Page 15
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III. Additional Review
In addition to reviewing concerns identified in the first review, Region 10 requested an update
about program resources and permit issuance progress and reviewed several permits that were
issued by SRCAA within the last few years. The following permits were reviewed by Region 10
as part of this program review:
The focus of the permit reviews was generally on previously identified concerns and specifically
on compliance assurance monitoring requirements. CAM has been a recent focus for Region 10's
oversight work for several reasons. CAM is required to be applied in the initial permit for
sources with "large" pollutant-specific emission units and in the first renewal for all other
emission units. Most pollutant-specific emission units are not large, so CAM has been primarily
implemented during the renewal phase of the Title V program. Region 10 had a rigorous permit
oversight program in the early years of Title V. By the time state and local agencies were issuing
renewal permits, Region 10 had scaled back its oversight program substantially and, in fact,
reviewed very few permits that addressed CAM. Beginning in fiscal year 2013, Region 10 began
to review a small percentage of state/local renewal permits to see how CAM was being
addressed. A consistent lack of documentation regarding CAM applicability and monitoring
decisions in statements of basis was discovered. Logically, Region 10 decided to specifically
review how CAM was being addressed in permits as part of the second-round program reviews.
Conclusions regarding past concerns have been documented in Section II of this report, specific
to each previously-identified concern. Concerns regarding CAM and any new topics identified
during the program review are documented in this section of the report.
New Concerns
1. Based on Region 10's review of SRCAA's permits, CAM applicability decisions were
sometimes missing or incomplete. Every statement of basis should address CAM
applicability in enough detail to clearly establish whether CAM applies to each emission unit
in the permitted facility, preferably in a single "CAM section" of the statement of basis. One
statement of basis correctly explained that an emission unit was subject to CAM and that
some other emission units were not subject, but did not address all of the emission units or
applicable requirements and did not always support the claims with data/information.
Emissions data was not presented to support whether an emission unit had pre- or post-
control potential to emit greater than the major source thresholds, key information for CAM
applicability and applying CAM when it is applicable. Where a simple statement regarding
CAM applicability citing the applicability criteria is not adequate (sometimes it can be) or
there are a lot of emission units potentially subject to CAM, Region 10 suggests SRCAA
consider using a tabular approach for documenting CAM applicability. Finally, when an
emission unit is subject to CAM, all the general CAM requirements in 40 CFR 64.2 through
64.10 must be included in the permit complete with citations to the EPA's and Washington's
rules as appropriate. Finally, SRCAA should ensure that the monitoring data collection
frequency for the emission unit subject to CAM meets CAM's minimum requirement.
SRCAA should improve the way CAM is addressed in their permit and statements of basis.
Permit No.
Company Name (Location)
Spokane Northside Landfill
Melcher Manufacturing Company
Kaiser Aluminum
Date Issued
07/17/2017
01/29/2018
10/30/2017
AOP-16
AOP-15
AOP-11
SRCAA Title V Program Review - 2018
Page 16
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2. The statements of basis included discussions about new applicable requirements; however,
the new requirement section was not consistently labeled as such. At least one statement of
basis can be improved by creating (and identifying as such) a section dedicated exclusively to
new applicable requirements and rules and address applicability to those new rules. Also, all
the statements of basis would benefit from the inclusion of a table of contents.
3. In some permits where MACT standards have been incorporated, multiple compliance
options are listed. In those cases where the compliance option chosen by the source is clear,
the statement of basis can explain that. If the other options are no longer possible, the permit
can also be cleaned up by removing the compliance options not used. Similarly, when
incorporating new applicable requirements, adding the details of all the compliance options,
rather than simply noting that several exist, is necessary.
4. One permit reviewed seems to assume that the state of Washington is implementing an EPA-
approved state plan rather than the federal plan. Region 10 has not approved the state of
Washington's plan. See 40 CFR 62.14352(b). The permit should be revised to include the
requirements in the applicable federal plan.
5. Many offices and units within Region 10 have new mailing addresses. Where SRCAA
includes the address for mailing copies of certain documents to Region 10, the permits
should be revised accordingly. Region 10 can supply the new addresses if needed.
SRCAA Title V Program Review - 2018
Page 17
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IV. Summary of Concerns and Recommendations
Concerns
Many of the concerns identified in the first-round program review have been resolved to Region
10's satisfaction, but some still need at least some attention. Region 10 is satisfied with
SRCAA's progress on 15 of the 20 concerns identified in the 2006 program review. Region 10
thinks SRCAA can still improve on the remaining five original concerns. Region 10 has
identified four new concerns that SCRAA should address.
Region 10 has provided some new information regarding two topics. Region 10 clarified that
fee revisions by SRCAA are not required to be submitted for approval, but Region 10 would
appreciate being kept apprised of fee revisions. If Region 10 ever thinks approval is necessary
for a particular fee revision, it will contact SRCAA (Concern 1-1). The mailing address for
sending reports to Region 10 has changed; SRCAA can update their permits with the new
address (New Concern 5).
SRCAA has made some improvements to their permits and statements of basis, but more
improvements can be realized for four original concerns and three new concerns. Better
documentation of major source status should be addressed in statements of basis (Concern A-4).
The types of alternative test methods that SRCAA can approve should be clarified in the permits
(Concern C-l). Historical compliance information should be documented in the statement of
basis and used to set the frequency of required source testing (Concern C-4). Deviations should
be better defined in permits to ensure better compliance and enforcement (Concern F-l).
SRCAA's statements of basis can be improved by consistently including a specific section that
addresses new applicable requirements (New Concern 2). Where MACT standards (for example)
allow several options for compliance and the company has selected the approach they will take,
the permit and statement of basis can clarify that (New Concern 3). A federal requirement was
not included in one permit (New Concern 4).
Region 10 is particularly concerned about one issue identified in 2006 as well as one new
issues. SRCAA has been consistently behind in issuing renewal permits. All three of the permits
that were issued within the last year had been administratively extended. Four more permits were
administratively extended this year. SRCAA must develop a plan to address their current and
seemingly recurring backlog (Concern E-l). Compliance assurance monitoring applicability
should be fully documented in the statement of basis (New Concern 1).
Recommendations
SRCAA should provide to Region 10 a response that explains what they plan to do to resolve
these 9 topics/concerns: Concern A-4, C-l, C-4, E-l and F-l and New Concerns 1 thru 4. If
SRCAA prefers to discuss any of the concerns before responding, Region 10 will gladly
accommodate that.
SRCAA Title V Program Review - 2018
Page 18
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sr<%, UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
* REGION 10
< £ 1200 Sixth Avenue, Suite 155
| "¦ Seattle, WA 98101-3123
OFFICE OF
AIR AND WASTE
July 9, 2018
Ms. Julie Oliver
Executive Director
Spokane Regional Clean Air Agency
3104 East Augusta Avenue
Spokane, Washington 9920?
Dear Ms. Oliver:
The purpose of this letter is to notify you that the U.S. Environmental Protection Agency Region 10 plans to perform a
second review of the Spokane Regional Clean Air Agency's title V operating permit program. This letter kicks off the
effort by describing the review process and our proposed schedule. We are also requesting information that will assist
us in our program review. Your agency will be the eighth of the second-round program reviews that Region 10 will
undertake.
This program review will focus primarily on the following four areas; (1) follow-up on concerns identified during
our 2006 review of your program; (2) permit issuance progress and resources; (3) compliance assurance monitoring;
and (4) new applicable requirements and rules. We will review a selection of your permits, focusing on those issued
more recently. This program review will require involvement of staff and managers from your permitting, technical,
finance and compliance groups. We appreciate your cooperation and assistance.
Our tentative schedule is as follows:
Task
Tentative Date
Region 10 sends kickoff letter
Today
You send requested information
July 27, 2018
Region 10 visits Spokane Clean Air
August 7-8, 2018
Region 10 sends final report
September 21, 2018
The enclosure describes the information we would like to receive in advance, so we can be efficient during the onsite
interviews. Please return the information (preferably in electronic form) as early as possible, but no later than the date
in the table above, to Doug Hardesty (hardesty.doug@epa.gov) who will be leading the review. We will contact you if
we need any additional information.
We look forward to working with you and your staff. If you have any questions about the program review, please
do not hesitate to call me at (206) 553-1679 or Doug at (208) 378-5759.
Sincerely,
1 i-V y.-j i fr-;):.,!^.
Kelly McFadden, Manager
Stationary Source Unit
Enclosure
cc:
Ms. April Westby, SRCAA (electronic)
-------
Title V Program Review
Spokane Regional Clean Air Agency
Information Request
Please send the following information in electronic form as soon as possible, but no later than July 27, 2018, to Doug
Hardesty (hardesty.doug@epa.gov)
1. A list of Spokane Clean Air staff that work in the title V program, noting their responsibilities (e.g. permit
writer, rule writer, inspector, etc.).
2. Information about any title V permits, renewals, or revisions that are recent enough that they are not
represented on the Spokane Clean Air website.
3. A list and description of any rule changes that have been made to Spokane Clean Air's title V regulations (e.g.
those that affect applicability, implementation, or fees) since the last revision approved in January, 2003. If any
of the rule changes have been submitted to Region 10 for review, note the date of submittal.
4. Financial records (preferably from your last complete fiscal year) reflecting revenues and expenses that
document Spokane Clean Air's ability to fund the operating permit program with title V fees and Spokane
Clean Air's ability to ensure that title V fees are used only for title V authorized expenses.
5. An update regarding each of the concerns raised in the 2006 title V program review, noting whether the plan to
address the concern was completed and whether Spokane Clean Air is approaching any of the concerns
identified in the 2006 title V program review differently than previously communicated to Region 10 on
August 7, 2006. Provide a narrative explaining the different approach, if applicable.
6. Any issues or requests that Spokane Clean Air would like to raise to Region 10 regarding any aspect of the title
V program.
-------
From:
To:
Subject:
Date:
April Westby
Hardestv. Doug
Title V information request numbers 1 and 2
Monday, July 23, 2018 11:23:48 AM
1) List of Spokane Regional Clean Air Agency staff that work in Title V program:
April Westby, permit writer (lead)
Joe Southwell, permit writer
Brandy Dickinson, inspector
Lori Rodriguez, Compliance Manager
Amy Fanning, Finance & Fluman Resources Manager
Julie Oliver, Executive Director
2) There is no title V permit information on permits, renewals, or revisions that is not
represented on the Spokane Clean Air website.
April Westby, PE
Environmental Engineer
Spokane Regional Clean Air Agency
3104 E. Augusta
Spokane, WA 99207
(509) 477-4727, ext. 105
awestby@spokanecleanair.org
-------
From:
To:
Subject:
Date:
April Westby
Hardestv. Doug
Title V information request item number 3
Monday, July 23, 2018 1:21:22 PM
SRCAA follows Chapter 173-401 WAC for Title V regulations. However, we do have our own fee
regulation. SRCAA's fee regulations have been revised 3 times since 2003, as follows:
Title V fees revised 9/7/06 through Resolution 06-16
Title V fees revised 7/3/08 through Resolution 08-18
Title V fees revised 10/3/13 through Resolutions 13-19 and 13-20.
I will send documents pertaining to each fee regulation revision in separate e-mails to keep them
clear.
April Westby, PE
Environmental Engineer
Spokane Regional Clean Air Agency
3104 E. Augusta
Spokane, WA 99207
(509) 477-4727, ext. 105
awestby@spokanecleanair.org
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Spokane Regional Clean Air Agency
Summary of Air Operating Permit Program
Program Cost and Fees Collected
FY
.. . Base Fee Emission fee Staff Time Fee
Billed
Total Fee(s)
Ecology Assessment
PassTh rough
Prior FY
Adjustment
Total
Actual
Program Costs
Variance
(Fees less Actual)
FY-14
$ 30,000.00
$ 88,382.13
$ 52,166.87
$ 170,549.00
$ 16,178.23
$ 36,331.01
$ 223,058.24
$ 137,545.00
$ 33,004.00
FY-15
$ 24,000.00
$ 81,712.72
$ 31,832.28
$ 137,545.00
$ 11,346.94
$ (33,004.00)
$ 115,887.94
$ 159,708.00
$ (22,164.00)
FY-16
$ 27,000.00
$ 78,295.94
$ 54,412.06
$ 159,708.00
$ 11,109.09
$ 22,164.00
$ 192,981.09
$ 175,764.00
$ (16,056.00)
FY-17
$ 27,000.00
$ 80,236.04
$ 68,527.96
$ 175,764.00
$ 10,772.02
$ 16,056.00
$ 202,592.02
$ 192,798.00
$ (17,034.00)
FY-18
$ 27,000.00
$ 80,096.84
$ 85,701.16
$ 192,798.00
$ 8,639.53
$ 17,034.00
$ 218,471.53
$
$ 192,798.00
G:\Baker\AIR QUALITY\Air Permits\Title V\Part 70 Program Reviews\SRCAA\2018\lnfo from SRCAA\4 - AOP Actual Costs vs Fees.xlsxFY14-18
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Office of the Washington State Auditor
Pat McCarthy
INDEPENDENT ACCOUNTANT'S REPORT ON APPLYING
AGREED UPON PROCEDURES
Julie Oliver, Executive Director
Spokane Regional Clean Air Agency
3104 E. Augusta Avenue
Spokane, WA 99207-5384
To the Board of Directors and Management of Spokane Regional Clean Air Agency
We have performed the procedures enumerated below, which were agreed to by the management
of Spokane Regional Clean Air Agency and the Washington State Department of Ecology, related
to the Agency's Air Operating Permit (AOP) program and the Agency's compliance with program
requirements established by Chapter 70.94.161-. 162 of the Revised Code of Washington and
Chapter 173-401 of the Washington Administrative Code, for the periods ended June 30, 2017 and
2016.
The Agency's management is responsible for managing the AOP program, compliance with these
requirements, and for the accuracy of its financial records. The sufficiency of these procedures is
solely the responsibility of those parties specified in this report. Consequently, we make no
representation regarding the sufficiency of the procedures enumerated below either for the purpose
for which this report has been requested of for any other purpose.
Agreed Upon Procedures
Results of Procedures
In relation to the Spokane Regional Clean
Air Agency's Air Operating Permit
(AOP) program:
Procedures related to collection of fees
1. Inspect the Authority's written
procedure for developing, assessing
and collecting fees from its sources
1. We inspected the Agency's written
procedures for developing, assessing,
and collecting fees from its sources and
Insurance Building, P.O. Box 40021 • Olympia, Washington 98504-0021 • (360) 902-0370 Pat.McCarthy@sao.wa.gov
-------
and determine whether it is more than
three years old.
2. Compare totals from the AOP permit
ledgers or systems to the general
ledger for each fiscal year.
(Applicable only if permits were
issued out of a separate system than
the general ledger and may only be
feasible if permit amounts are
included in the permit ledger or
system.)
3. Judgmentally select AOP permits
issued during the engagement period
and trace amounts to receipts and to
the general ledger.
4. Inspect a judgmental selection of
AOP permit accounts receivables for
each fiscal year and determine
whether late fees were assessed and
collection measures initiated in
accordance with Authority policies
and procedures.
Procedures related to computation
of fees
5. Inspect invoices for a judgmental
selection of AOP permits issued
during the engagement period to
ensure fees agreed with the
Authority's approved fee schedule
and fee calculation worksheets.
Procedures related to revenue and
expenditure accounting
6. Identify which fund or accounts are
used to account for AOP revenue and
expenses.
found they were updated on
January 4, 2018, which is less than
three years old.
2. We did not perform this procedure. The
Agency issues all permits from its
general ledger and a separate system is
not used.
3. We selected all AOP permits issued
during the periods ended June 30, 2017
and 2016 and traced corresponding
receipt amounts to the general ledger.
No exceptions were found as a result of
applying this procedure.
4. We did not perform this procedure. We
traced all billings for AOP permits to
actual payments and there were no AOP
permit receivables for either fiscal year.
5. We selected all invoices for AOP
permits issued during the engagement
period and confirmed that fees agreed to
the approved fee schedule and fee
calculation worksheet.
6. AOP revenues are accounted for in
Fund 131. Expenses charged directly to
the AOP program are accounted for in
Fund 131.
-------
7. Inspect all Authority general ledger
accounts used to account for AOP
revenue and expenses and determine
whether AOP revenue and expenses
are commingled with other revenue
sources or expense uses.
8. Judgmentally select expenses
accounted for in non-AOP accounts
during the engagement period and
inspect supporting documentation to
determine whether they were for
AOP activities.
7. We inspected general ledger accounts
for Fund 131 and determined that AOP
revenues and expenses are not
comingled with other revenue sources or
expense uses.
8. We judgmentally selected expense
transactions from non-AOP accounts
that occurred during the engagement
period and inspected supporting
documentation for each and determined
they were not related to AOP activities.
Procedures related to authorized
activities
9. Judgmentally select AOP program
expenses (including payroll) for the
engagement period and inspect
supporting documentation to
determine whether they were for
allowable program activities.
10. Inspect supporting documentation for
a judgmental selection of tasks the
sources were billed for during the
engagement period and determine
whether they were completed.
11. Inspect the Authority's indirect costs
allocations and determine whether
indirect costs were also charged to the
program as direct costs.
Procedures related to available
funds
12. Inspect Authority interim and year-
end balance sheets for each fiscal year
to determine if the AOP program had
a negative fund balance at any time
during the engagement period.
9. We judgmentally selected expenses
charged to the AOP program during the
engagement period and determined they
were for allowable program activities.
10. We inspected supporting documentation
for a judgmental selection of permit
issuances which sources were billed for
during the engagement period
and determined that these tasks had been
completed.
11. We inspected the Agency's indirect cost
allocations and determined that indirect
costs were not also charged to the
program as direct costs.
12. We inspected year-end balance sheets
for each fiscal year and determined that
the AOP program did not have a
negative fund balance at any time during
the engagement period.
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13. Inspect uses of AOP program
revenues collected in excess of actual
program costs for each fiscal year and
determine whether Authority
complied with its policy for handling
excess program revenue.
14. To ensure all Title V facilities were
billed for permit fees during the
engagement period, perform a query
of all Title V sources and synthetic
minors on an annual basis.
13. We compared AOP program revenues to
program costs for each fiscal year and
determined that there were no excess
program revenues during the
engagement period.
14. We obtained list of all permits issued by
the Agency for Title V sources and
synthetic minors for the engagement
period. We compared this list to billings
and collections for the same period and
determined that all facilities were billed
for permit fees.
This agreed-upon procedures engagement was conducted in accordance with attestation standards
established by the American Institute of Certified Public Accountants, and the standards applicable
to attestation engagements contained in Government Auditing Standards, issued by the Comptroller
General of the United States. We were not engaged to and did not conduct an examination or
review, the objectives of which would be the expression of an opinion or conclusion on the
financial information of the Agency's AOP program, on compliance with specified requirements,
or on the internal control over compliance with the specified requirements. Additionally, the
agreed-upon procedures do not constitute an audit or review of financial statements or any part
thereof, the objective of which is the expression of an opinion or conclusion, respectively, on the
financial statements or a part thereof. Accordingly, we do not express such an opinion or
conclusion. Had we performed additional procedures, other matters might have come to our
attention that would have been reported to you.
Restriction on Use
This report is intended for the information and use of the Board of Directors and Management of
the Spokane Regional Clean Air Agency and the Department of Ecology and is not suitable for
any other purpose. However, this report is a matter of public record and its distribution is not
limited.
Sincerely,
Bradley White, Audit Manager
Washington State Auditor's Office
Spokane, Washington
April 9, 2018
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Fee Calculations for 2017 Billing
Emission Totals based on WEDs submitted in April 2017 (covering calendar year 2016 emissions)
10/18/2017
PM10
S02
NOx
VOC
CO
Non VOC TAPs
TOTAL
COMPANY NO.
SOURCE
tpy
tpy
tpy
tpy
tpy
tpy
TPY
506
FIBER-TECH
0.07
0.00
0.00
54.85
0.00
0.00
54.92
529
IEPC
51.70
0.20
68.20
7.50
8.20
1.82
137.62
483
KAISER TRENTWOOD
82.20
0.70
115.30
188.30
116.90
0.99
504.39
505
MELCHER MANUF
0.34
0.00
0.00
4.87
0.00
0.00
5.21
270
MUTUAL MATERIALS
47.28
17.84
9.44
0.64
31.89
30.32
137.41
300
NORTHSIDE LANDFILL
0.61
0.06
0.45
0.09
0.93
0.58
2.72
107
TRANSCANADA GTN
4.20
2.30
73.10
6.90
62.10
0.00
148.60
765
HAAKON
0.32
0.00
0.00
16.69
0.00
0.00
17.01
503
WTE
20.60
6.20
306.40
0.90
27.50
11.50
373.10
TOTAL
207.3
27.3
572.9
280.7
247.5
45.2
1,380.98
1,381.0
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Fee Calculations for 2017 Billing
CY-2017 AOP Fee Calculations
Based on FY 17 Program Costs and
SRCAA Regulation I, Section 10.06
11/16/2017
Base Fee Emission Fee
Total Base Fee &
Emission Fee
$58.00
BASED ON WEDS
COMPANY NO.
SOURCES
2016 EMISSIONS
Base Fee
Emission Fee
Total Base Fee
and Emission Fee
506
FIBER T
54.92
$3,000.00
$3,185.36
$6,185.36
529
IEPC
137.62
$3,000.00
$7,981.96
$10,981.96
483
KAISER TRENTWOOD
504.39
$3,000.00
$29,254.62
$32,254.62
505
MELCHER MANUF
5.21
$3,000.00
$302.18
$3,302.18
270
MUTUAL MATERIALS
137.41
$3,000.00
$7,969.78
$10,969.78
300
NORTHSIDE LANDFILL
2.72
$3,000.00
$157.76
$3,157.76
107
GTN
148.60
$3,000.00
$8,618.80
$11,618.80
765
HAAKON
17.01
$3,000.00
$986.58
$3,986.58
503
WTE
373.10
$3,000.00
$21,639.80
$24,639.80
TOTAL
1380.98 | $27,000.00| $80,096.84| $107,096.84
SRCAA Time
Fee
SRCAA Time
Fee
1,287.63
$9,991.60
$33,232.38
$3,321.95
$4,519.40
$10,171.86
$6,180.37
$2,472.15
$11,523.82
$85,701.16
Total FY 2017 AOP
Program Cost =
$192,798.00
SRCAA Time Fee
must cover balance
$192,798 -$107,096.84 =
$85,701.16
Total Annual
Fee
$10,472.99
$20,973.56
$65,487.00
$6,624.13
$15,489.18
$13,329.62
$17,799.17
$6,458.73
$36,163.62
| $192,798^00]
SRCAA AOP
Program Cost Correction
Total SRCAA Fee
$17,034.00
SRCAA Program
Cost Correction
$925.31
$1,853.05
$5,785.88
$585.25
$1,368.49
$1,177.69
$1,572.58
$570.64
$3,195.11
$17,034.00|
TOTAL SRCAA
FEE
$11,398.30
$22,826.61
$71,272.87
$7,209.38
$16,857.67
$14,507.32
$19,371.76
$7,029.37
$39,358.73
$209,832.00]
This amount accounts
for the difference between
the FY-16 and FY-17 costs
Ecology Assessment
TOTAL AOP FEE
Ecology Assessment
$8,639.53
Ecology
Assessment
$469.31
$939.85
$2,934.56
$296.84
$694.09
$597.32
$797.60
$289.42
$1,620.54
$8,639.53|
TOTAL AOP
FEE
$11,867.61
$23,766.46
$74,207.43
$7,506.22
$17,551.76
$15,104.63
$20,169.36
$7,318.79
$40,979.27
$218,471.53|
Ecology assessment =
$8,639.53
FY-16 program cost
$175,764
$8,639.53 will be sent
to Ecology
-------
SRCAATime Fee Calculation
CY 2017 Billing
11/16/2017
Total Number of General Hours
Total Number of Hours
Spent on AOP During FY 2017 =
Total Hours
COMPANY NO.
SOURCES
Spent During FY 2017
339.75/9 = 37.75 hrs/source
Hrs/Yr
506
FIBER-TECH
45.5
37.75
83.25
529
IEPC
156.25
37.75
194.00
483
KAISER TRENTWOOD
607.5
37.75
645.25
505
MELCHER MANUF
26.75
37.75
64.50
270
MUTUAL MATERIALS
50
37.75
87.75
300
NORTHSIDE LANDFILL
159.75
37.75
197.50
107
TRANSCANADA GTN
82.25
37.75
120.00
765
HAAKON
10.25
37.75
48.00
503
WTE
186
37.75
223.75
ITOTAL
1324.25
339.75
1664
TOTAL AMOUNT FOR
SRCAATIME FEE =
SRCAA Time Fee
$4,287.63
$9,991.60
$33,232.38
$3,321.95
$4,519.40
$10,171.86
$6,180.37
$2,472.15
$11,523.82
| $85,701.16|
$85,701.16
339.75 hrs
-------
2017 AOP Billing
Summary Spreadsheet
11/16/2017
COMPANY NO.
SOURCES
TOTAL
TPY
506
FIBER T
54.92
529
IEPC
137.62
483
KAISER TRENTWOOD
504.39
505
MELCHER MANUF
5.21
270
MUTUAL MATERIALS
137.41
300
NORTHSIDE LANDFILL
2.72
107
GTN
148.6
765
HAAKON
17.01
503
WTE
373.1
TOTAL
1380.98
2017
Base Fee
Emission Fee
SRCAA Time
SRCAAAOP
Total SRCAA
Ecology
Fee
Program Cost Correction
Fee
Assessment
$3,000.00
$3,185.36
$4,287.63
$925.31
$11,398.30
$469.31
$3,000.00
$7,981.96
$9,991.60
$1,853.05
$22,826.61
$939.85
$3,000.00
$29,254.62
$33,232.38
$5,785.88
$71,272.87
$2,934.56
$3,000.00
$302.18
$3,321.95
$585.25
$7,209.38
$296.84
$3,000.00
$7,969.78
$4,519.40
$1,368.49
$16,857.67
$694.09
$3,000.00
$157.76
$10,171.86
$1,177.69
$14,507.32
$597.32
$3,000.00
$8,618.80
$6,180.37
$1,572.58
$19,371.76
$797.60
$3,000.00
$986.58
$2,472.15
$570.64
$7,029.37
$289.42
$3,000.00
$21,639.80
$11,523.82
$3,195.11
$39,358.73
$1,620.54
$27,000.00 | $80,096.84 | $85,701.16 I
$17,034.00 r
Fee Goes to Fee Goes to
SRCAAAOP SRCAAAOP
Program Program
Fee Goes to
SRCAA AOP
Program
Amount Goes to repay
general fund
$209,832.00 | $8,639.53 |
$8,639.53 will
be sent to
Ecology
I $218,471.53]
$192,798.00
-------
Office of the Washington State Auditor
Pat McCarthy
Financial Statements Audit Report
Spokane Regional Clean Air Agency
Spokane County
For the period July 1, 2015 through June 30, 2017
Published April 26, 2018
Report No. 1021148
0SJ 0
-------
Office of the Washington State Auditor
Pat McCarthy
April 26, 2018
Board of Directors
Spokane Regional Clean Air Agency
Spokane, Washington
Report on Financial Statements
Please find attached our report on the Spokane Regional Clean Air Agency's financial statements.
We are issuing this report in order to provide information on the Agency's financial condition.
Sincerely,
Pat McCarthy
State Auditor
Olympia, WA
Insurance Building, P.O. Box 40021 • Olympia, Washington 98504-0021 • (360) 902-0370 • Pat.McCarthy@sao.wa.gov
-------
TABLE OF CONTENTS
Independent Auditor's Report on Internal Control Over Financial Reporting and on Compliance
and Other Matters Based on an Audit of Financial Statements Performed in Accordance with
Government Auditing Standards 4
Independent Auditor's Report on Financial Statements 7
Financial Section 11
About the State Auditor's Office 39
Washington State Auditor's Office Page 3
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INDEPENDENT AUDITOR'S REPORT ON INTERNAL CONTROL
OVER FINANCIAL REPORTING AND ON COMPLIANCE AND
OTHER MATTERS BASED ON AN AUDIT OF FINANCIAL
STATEMENTS PERFORMED IN ACCORDANCE WITH
GOVERNMENT AUDITING STANDARDS
Spokane Regional Clean Air Agency
Spokane County
July 1, 2015 through June 30, 2017
Board of Directors
Spokane Regional Clean Air Agency
Spokane, Washington
We have audited, in accordance with auditing standards generally accepted in the United States of
America and the standards applicable to financial audits contained in Government Auditing
Standards, issued by the Comptroller General of the United States, the financial statements of the
Spokane Regional Clean Air Agency, Spokane County, Washington, as of and for the years ended
June 30, 2017 and 2016, and the related notes to the financial statements, which collectively
comprise the Agency's financial statements, and have issued our report thereon dated April 9,
2018.
We issued an unmodified opinion on the fair presentation of the Agency's financial statements in
accordance with its regulatory basis of accounting. We issued an adverse opinion on the fair
presentation with regard to accounting principles generally accepted in the United States of
America (GAAP) because the financial statements are prepared by the Agency using accounting
practices prescribed by Washington State statutes and the State Auditor's Budge ling, Accounting
and Reporting System (BARS) manual described in Note 1, which is a basis of accounting other
than GAAP. The effects on the financial statements of the variances between the basis of
accounting described in Note 1 and accounting principles generally accepted in the United States
of America, although not reasonably determinable, are presumed to be material.
INTERNAL CONTROL OVER FINANCIAL REPORTING
In planning and performing our audits of the financial statements, we considered the Agency's
internal control over financial reporting (internal control) to determine the audit procedures that
are appropriate in the circumstances for the purpose of expressing our opinions on the financial
statements, but not for the purpose of expressing an opinion on the effectiveness of the Agency's
Washington State Auditor's Office
Page 4
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internal control. Accordingly, we do not express an opinion on the effectiveness of the Agency's
internal control.
A deficiency in internal control exists when the design or operation of a control does not allow
management or employees, in the normal course of performing their assigned functions, to prevent,
or detect and correct, misstatements on a timely basis. A material weakness is a deficiency, or a
combination of deficiencies, in internal control such that there is a reasonable possibility that a
material misstatement of the Agency's financial statements will not be prevented, or detected and
corrected on a timely basis. A significant deficiency is a deficiency, or a combination of
deficiencies, in internal control that is less severe than a material weakness, yet important enough
to merit attention by those charged with governance.
Our consideration of internal control was for the limited purpose described in the first paragraph
of this section and was not designed to identify all deficiencies in internal control that might be
material weaknesses or significant deficiencies. Given these limitations, during our audit we did
not identify any deficiencies in internal control that we consider to be material weaknesses.
However, material weaknesses may exist that have not been identified.
COMPLIANCE AM) OTHER MATTERS
As part of obtaining reasonable assurance about whether the Agency's financial statements are
free from material misstatement, we performed tests of the Agency's compliance with certain
provisions of laws, regulations, contracts and grant agreements, noncompliance with which could
have a direct and material effect on the determination of financial statement amounts. However,
providing an opinion on compliance with those provisions was not an objective of our audit, and
accordingly, we do not express such an opinion.
The results of our tests disclosed no instances of noncompliance or other matters that are required
to be reported under Government Auditing Standards.
PURPOSE OF THIS REPORT
The purpose of this report is solely to describe the scope of our testing of internal control and
compliance and the results of that testing, and not to provide an opinion on the effectiveness of the
Agency's internal control or on compliance. This report is an integral part of an audit performed
in accordance with Government Auditing Standards in considering the Agency's internal control
and compliance. Accordingly, this communication is not suitable for any other purpose. However,
Washington State Auditor's Office
Page 5
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this report is a matter of public record and its distribution is not limited. It also serves to
disseminate information to the public as a reporting tool to help citizens assess government
operations.
Pat McCarthy
State Auditor
Olympia, WA
April 9, 2018
Washington State Auditor's Office
Page 6
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INDEPENDENT AUDITOR'S REPORT ON
FINANCIAL STATEMENTS
Spokane Regional Clean Air Agency
Spokane County
July 1, 2015 through June 30, 2017
Board of Directors
Spokane Regional Clean Air Agency
Spokane, Washington
REPORT ON THE FINANCIAL STATEMENTS
We have audited the accompanying financial statements of the Spokane Regional Clean Air
Agency, Spokane County, Washington, for the years ended June 30,2017 and 2016, and the related
notes to the financial statements, which collectively comprise the Agency's financial statements,
as listed on page 11.
Management's Responsibility for the Financial Statements
Management is responsible for the preparation and fair presentation of these financial statements
in accordance with the financial reporting provisions of Washington State statutes and the
Budgeting, Accounting and Reporting System (BARS) manual prescribed by the State Auditor
described in Note 1. This includes determining that the basis of accounting is acceptable for the
presentation of the financial statements in the circumstances. Management is also responsible for
the design, implementation and maintenance of internal control relevant to the preparation and fair
presentation of financial statements that are free from material misstatement, whether due to fraud
or error.
Auditor's Responsibility
Our responsibility is to express opinions on these financial statements based on our audits. We
conducted our audits in accordance with auditing standards generally accepted in the United States
of America and the standards applicable to financial audits contained in Government Auditing
Standards, issued by the Comptroller General of the United States. Those standards require that
we plan and perform the audit to obtain reasonable assurance about whether the financial
statements are free from material misstatement.
Washington State Auditor's Office
Page 7
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An audit involves performing procedures to obtain audit evidence about the amounts and
disclosures in the financial statements. The procedures selected depend on the auditor's judgment,
including the assessment of the risks of material misstatement of the financial statements, whether
due to fraud or error. In making those risk assessments, the auditor considers internal control
relevant to the Agency's preparation and fair presentation of the financial statements in order to
design audit procedures that are appropriate in the circumstances, but not for the purpose of
expressing an opinion on the effectiveness of the Agency's internal control. Accordingly, we
express no such opinion. An audit also includes evaluating the appropriateness of accounting
policies used and the reasonableness of significant accounting estimates made by management, as
well as evaluating the overall presentation of the financial statements.
We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis
for our audit opinions.
Unmodified Opinion on Regulatory Basis of Accounting (BARS Manual)
As described in Note 1, the Spokane Regional Clean Air Agency has prepared these financial
statements to meet the financial reporting requirements of Washington State statutes using
accounting practices prescribed by the State Auditor's Budgeting, Accounting and Reporting
System (BARS) manual. Those accounting practices differ from accounting principles generally
accepted in the United States of Atnerica (GAAP). The differences in these accounting practices
are also described in Note 1.
In our opinion, the financial statements referred to above present fairly, in all material respects,
the financial position and results of operations of the Spokane Regional Clean Air Agency, for the
years ended June 30, 2017 and 2016, on the basis of accounting described in Note 1.
Basis for Adverse Opinion on U.S. GAAP
Auditing standards issued by the American Institute of Certified Public Accountants (AICPA)
require auditors to formally acknowledge when governments do not prepare their financial
statements, intended for general use, in accordance with GAAP. The effects on the financial
statements of the variances between GAAP and the accounting practices the Agency used, as
described in Note 1, although not reasonably determinable, are presumed to be material. As a
result, we are required to issue an adverse opinion on whether the financial statements are
presented fairly, in all material respects, in accordance with GAAP.
Washington State Auditor's Office
Page 8
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Adverse Opinion on U.S. GAAP
The financial statements referred to above were not intended to, and in our opinion they do not,
present fairly, in accordance with accounting principles generally accepted in the United States of
America, the financial position of the Spokane Regional Clean Air Agency, as of June 30, 2017
and 2016, or the changes in financial position or cash flows for the years then ended, due to the
significance of the matter discussed in the above "Basis for Adverse Opinion on U.S. GAAP"
paragraph.
Other Matters
Supplementary and Other In formation
Our audits were performed for the purpose of forming opinions on the financial statements taken
as a whole. The Schedules of Liabilities are presented for purposes of additional analysis, as
required by the prescribed BARS manual. These schedules are not a required part of the financial
statements. Such information is the responsibility of management and was derived from and
relates directly to the underlying accounting and other records used to prepare the financial
statements. The information has been subjected to the auditing procedures applied in the audit of
the financial statements and certain additional procedures, including comparing and reconciling
such information directly to the underlying accounting and other records used to prepare the
financial statements or to the financial statements themselves, and other additional procedures in
accordance with auditing standards generally accepted in the United States of America. In our
opinion, the information is fairly stated, in all material respects, in relation to the financial
statements taken as a whole.
OTHER REPORTING REQUIRED BY GOVERNMENT AUDITING
STANDARDS
In accordance with Government Auditing Standards, we have also issued our report dated April 9,
2018 on our consideration of the Agency's internal control over financial reporting and on our
tests of its compliance with certain provisions of laws, regulations, contracts and grant agreements
and other matters. The purpose of that report is to describe the scope of our testing of internal
control over financial reporting and compliance and the results of that testing, and not to provide
an opinion on internal control over financial reporting or on compliance. That report is an integral
Washington State Auditor's Office
Page 9
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part of an audit performed in accordance with Government Auditing Standards in considering the
Agency's internal control over financial reporting and compliance.
Pat McCarthy
State Auditor
Olympia, WA
April 9, 2018
Washington State Auditor's Office
Page 10
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FINANCIAL SECTION
Spokane Regional Clean Air Agency
Spokane County
July 1, 2015 through June 30, 2017
FINANCIAL STATEMENTS
Fund Resources and Uses Arising from Cash Transactions - 2017
Fund Resources and Uses Arising from Cash Transactions - 2016
Fiduciary Fund Resources and Uses Arising from Cash Transactions - 2017
Fiduciary Fund Resources and Uses Arising from Cash Transactions - 2016
Notes to the Financial Statements - 2017
Notes to the Financial Statements - 2016
SUPPLEMENTARY AND OTHER INFORMATION
Schedule of Liabilities - 2017
Schedule of Liabilities - 2016
Washington State Audi tor's Offi ce Page 11
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Spokane Regional Clean Air Agency
Fund Resources and Uses Arising from Cash Transactions
For the Year Ended June 30, 2017
Total for All
Funds
(Memo Only)
001 General
Fund
104 VERP III
129 Wood
Smoke
Reduction 16 &
Beginning Cash and Investments
30810
Reserved
681,804
249,232
7,621
-
30880
Unreserved
1,379,075
1,379,075
-
-
388/588
Prior Period Adjustments, Net
-
-
-
-
Revenues
320
Licenses and Permits
806
806
-
-
330
Intergovernmental Revenues
376,637
322,740
-
53,897
340
Charges for Goods and Services
1,098,916
-
-
-
350
Fines and Penalties
85,167
85,167
-
-
360
Miscellaneous Revenues
681,337
595,528
-
27,922
Total Revenues:
2,242,863
1,004,241
-
81,819
Expenditures
550
Natural and Economic
Environment
2,205,576
1,032,957
16,783
81,819
Total Expenditures:
2,205,576
1,032,957
16,783
81,819
Excess (Deficiency) Revenues over Expenditures:
37,287
(28,716)
(16,783)
0
Other Increases in Fund Resources
391-393, 596
Debt Proceeds
-
-
-
-
397
Transfers-ln
20,087
87
20,000
-
385
Special or Extraordinary Items
-
-
-
-
386/389
Custodial Activities
-
-
-
-
381, 395, 398
Other Resources
-
-
-
-
Total Other Increases in Fund Resources:
20,087
87
20,000
-
Other Decreases in Fund Resources
594-595
Capital Expenditures
3,794
3,794
-
-
591-593, 599
Debt Service
-
-
-
-
597
Transfers-Out
20,000
20,000
-
-
585
Special or Extraordinary Items
-
-
-
-
586/589
Custodial Activities
-
-
-
-
Total Other Decreases in Fund Resources:
23,794
23,794
-
-
Increase (Decrease) in Cash and Investments:
33,580
(52,423)
3,217
0
Ending Cash and Investments
5081000
Reserved
933,941
415,366
10,837
-
5088000
Unreserved
1,160,519
1,160,519
-
-
Total Ending Cash and Investments
2,094,460
1,575,885
10,837
-
The accompanying notes are an integral part of this statement.
Washington State Auditor's Office Page 12
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Spokane Regional Clean Air Agency
Fund Resources and Uses Arising from Cash Transactions
For the Year Ended June 30, 2017
131 Air
Operating 133 Source 134
Permit Title V 132 Asbestos Registration NOC/NOI/SEPA
Beginning Cash and Investments
30810 Reserved - 193,802 231,149
30880 Unreserved -
388 / 588 Prior Period Adjustments, Net -
Revenues
320 Licenses and Permits -
330 Intergovernmental Revenues -
340 Charges for Goods and Services 175,774 283,227 501,720 138,195
350 Fines and Penalties -
360 Miscellaneous Revenues 17,025 - - 40,862
Total Revenues: 192,799 283,227 501,720 179,057
Expenditures
550 Natural and Economic 192,799 202,716 499,445 179,057
Environment
Total Expenditures: 192,799 202,716 499,445 179,057
Excess (Deficiency) Revenues over Expenditures: 0 80,511 2,275
Other Increases in Fund Resources
391-393,596 Debt Proceeds -
397 Transfers-ln -
385 Special or Extraordinary Items -
386 / 389 Custodial Activities -
381,395,398 Other Resources -
Total Other Increases in Fund Resources: -
Other Decreases in Fund Resources
594-595 Capital Expenditures -
591-593, 599 Debt Service -
597 Transfers-Out -
585 Special or Extraordinary Items -
586 / 589 Custodial Activities -
Total Other Decreases in Fund Resources: -
Increase (Decrease) in Cash and Investments: 0 80,511 2,275
Ending Cash and Investments
5081000 Reserved - 274,313 233,424
5088000 Unreserved -
Total Ending Cash and Investments - 274,313 233,424
The accompanying notes are an integral part of this statement.
Washington State Auditor's Office
Page 13
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Spokane Regional Clean Air Agency
Fund Resources and Uses Arising from Cash Transactions
For the Year Ended June 30, 2016
Total for All
Funds
(Memo Only)
001 Current
Expense
104 VERP III
129 Wood
Smoke
Reduction 16 &
Beginning Cash and Investments
30810
Reserved
442,848
190,717
7,290
-
30880
Unreserved
1,546,548
1,546,548
-
-
388/588
Prior Period Adjustments, Net
-
-
-
-
Revenues
320
Licenses and Permits
679
679
-
-
330
Intergovernmental Revenues
368,701
317,951
-
50,750
340
Charges for Goods and Services
1,049,968
-
-
-
350
Fines and Penalties
99,290
99,290
-
-
360
Miscellaneous Revenues
650,517
572,690
-
-
Total Revenues:
2,169,156
990,611
-
50,750
Expenditures
550
Natural and Economic
Environment
1,976,996
958,891
19,670
50,750
Total Expenditures:
1,976,996
958,891
19,670
50,750
Excess (Deficiency) Revenues over Expenditures:
192,160
31,719
(19,670)
-
Other Increases in Fund Resources
391-393, 596
Debt Proceeds
-
-
-
-
397
Transfers-ln
20,000
-
20,000
-
385
Special or Extraordinary Items
-
-
-
-
386/389
Custodial Activities
-
-
-
-
381, 395, 398
Other Resources
-
-
-
-
Total Other Increases in Fund Resources:
20,000
-
20,000
-
Other Decreases in Fund Resources
594-595
Capital Expenditures
120,678
120,678
-
-
591-593, 599
Debt Service
-
-
-
-
597
Transfers-Out
20,000
20,000
-
-
585
Special or Extraordinary Items
-
-
-
-
586/589
Custodial Activities
-
-
-
-
Total Other Decreases in Fund Resources:
140,678
140,678
-
-
Increase (Decrease) in Cash and Investments:
71,482
(108,959)
330
-
Ending Cash and Investments
5081000
Reserved
681,804
249,232
7,621
-
5088000
Unreserved
1,379,075
1,379,075
-
-
Total Ending Cash and Investments
2,060,879
1,628,307
7,621
-
The accompanying notes are an integral part of this statement.
Washington State Auditor's Office
Page 14
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Spokane Regional Clean Air Agency
Fund Resources and Uses Arising from Cash Transactions
For the Year Ended June 30, 2016
131 Air
Operating 133 Source 134
Permit Title V 132 Asbestos Registration NOC/NOI/SEPA
Beginning Cash and Investments
30810 Reserved - 162,915 81,926
30880 Unreserved -
388 / 588 Prior Period Adjustments, Net -
Revenues
320 Licenses and Permits -
330 Intergovernmental Revenues -
340 Charges for Goods and Services 159,918 265,736 524,081 100,234
350 Fines and Penalties -
360 Miscellaneous Revenues 15,846 - - 61,982
Total Revenues: 175,764 265,736 524,081 162,215
Expenditures
550 Natural and Economic 175,764 234,848 374,858 162,215
Environment
Total Expenditures: 175,764 234,848 374,858 162,215
Excess (Deficiency) Revenues over Expenditures: 0 30,888 149,223 1
Other Increases in Fund Resources
391-393,596 Debt Proceeds -
397 Transfers-ln -
385 Special or Extraordinary Items -
386 / 389 Custodial Activities -
381,395,398 Other Resources -
Total Other Increases in Fund Resources: -
Other Decreases in Fund Resources
594-595 Capital Expenditures -
591-593, 599 Debt Service -
597 Transfers-Out -
585 Special or Extraordinary Items -
586 / 589 Custodial Activities -
Total Other Decreases in Fund Resources: -
Increase (Decrease) in Cash and Investments: 0 30,888 149,223
Ending Cash and Investments
5081000 Reserved - 193,802 231,149
5088000 Unreserved -
Total Ending Cash and Investments _ 193,802 231,149
The accompanying notes are an integral part of this statement.
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Spokane Regional Clean Air Agency
Fiduciary Fund Resources and Uses Arising from Cash Transactions
For the Year Ended June 30, 2017
Total for All 601 AOP DOE
Funds Oversight
(Memo Only)
308 Beginning Cash and Investments
388 & 588 Prior Period Adjustments, Net
310-360 Revenues 10,772 10,772
380-390 Other Increases and Financing Sources
510-570 Expenditures
580-590 Other Decreases and Financing Uses 10,772 10,772
Net Increase (Decrease) in Cash and - (0)
Investments:
508 Ending Cash and Investments
The accompanying notes are an integral part of this statement.
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Spokane Regional Clean Air Agency
Fiduciary Fund Resources and Uses Arising from Cash Transactions
For the Year Ended June 30, 2016
Total for All 601 AOP DOE
Funds Oversight
(Memo Only)
308 Beginning Cash and Investments
388 & 588 Prior Period Adjustments, Net
310-360 Revenues 11,197 11,197
380-390 Other Increases and Financing Sources
510-570 Expenditures
580-590 Other Decreases and Financing Uses 11,197 11,197
Net Increase (Decrease) in Cash and - 0
Investments:
508 Ending Cash and Investments
The accompanying notes are an integral part of this statement.
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Spokane Regional Clean Air Agency
MCAG 1026
Notes to the Financial Statements
For the year ended June 30, 2017
The Spokane Regional Clean Air Agency (SRCAA) was incorporated on January 1, 1969 and operates
under the laws of the state of Washington applicable to Air Pollution Control Agencies. SRCAA is a special
purpose government district and is responsible for administering federal, state, and local laws and
regulations regarding outdoor air pollution in Spokane County. To achieve the goals of the Clean Air Act,
SRCAA established programs aimed at reducing air pollution from all sources. The Agency directs a
combination of education and regulatory efforts towards commercial and industrial emission sources,
residential wood combustion, outdoor burning, motor vehicle, and asbestos, and dust sources.
• SRCAA operates an air monitoring network which gathers data and reports air quality and the
level of pollution for PM2.5 and PM10 to the public on an hourly basis. SRCAA also reports
air quality and the level of Ozone pollution on an hourly basis during Ozone season.
• SRCAA provides education and outreach to the public through direct contact at schools, local
events, website and social media.
• SRCAA issues air permits to businesses that create air emissions such as auto body painting,
gas stations, large industrial facilities, and others.
• SRCAA provides Air Quality maintenance planning and monitoring to ensure continued
attainment of the Federal Air Quality Standards for Spokane County.
• SRCAA serves the public by responding to complaints and enforcing State, Federal, and Local
Air Quality regulations according to the Washington State Clean Air Act Chapter 70.94 RCW.
A five-member Board of Directors governs SRCAA. The Board is made up of one County Commissioner,
one representative from City of Spokane, one representative from City of Spokane Valley, one
representative from the small cities and towns, and one member at large elected by the Board. The Board
appoints an Executive Director to oversee the Agency's daily operations and its 18 employees.
The Spokane Regional Clean Air Agency reports financial activity in accordance with the Cash Basis
Budgeting, Accounting and Reporting System (BARS) Manual prescribed by the State Auditor's Office
under the authority of Washington State law, Chapter 43.09 RCW. This manual prescribes a financial
reporting framework that differs from generally accepted accounting principles (GAAP) in the following
manner:
• Financial transactions are recognized on a cash basis of accounting as described below.
• Component units are required to be disclosed, but are not included in the financial statements.
• Government-wide statements, as defined in GAAP, are not presented.
• All funds are presented, rather than a focus on major funds.
• The Schedule of Liabilities is required to be presented with the financial statements as
supplementary information.
• Supplementary information required by GAAP is not presented.
• Ending balances are not presented using the classifications defined in GAAP.
A. Fund Accounting
Financial transactions of the government are reported in individual funds. Each fund uses a
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separate set of self-balancing accounts that comprises its cash and investments, revenues and
expenditures. The government's resources are allocated to and accounted for in individual funds
depending on their intended purpose. Each fund is reported as a separate column in the financial
statements. The following fund types are used by SRC A A:
GOVERNMENTAL FUND TYPES:
General Fund
This fund is the primary operating fund of SRCAA. It accounts for all financial resources except
those required or elected to be accounted for in another fund.
The following funds have been established by Resolution and adopted by the Board of Directors as
designated reserves that have been elected to be accounted for in separate funds. These funds roll-up
into the general fund for reporting purposes. A Resolution must be approved by the Board of
Directors to appropriate expenditures or transfer any portion of the fund balance to another fund.
• 002 Petty Cash
• 005 Project Reserve
• 006 Retirement Reserve
• 007 Monitoring Equipment Reserve
• 008 Vehicle Reserve
• 009 Building Maintenance Reserve
• 010 Information Technology (IT) Reserve
• 011 Ozone Study Reserve
Special Revenue Funds
These funds account for specific revenue sources that are restricted or committed to expenditures
for specified purposes of the government.
• 104 VERPIII
• 129 Wood Smoke Reduction (State Grant)
The following funds account for operations that provide goods or services to the general public
and are supported primarily through user charges. Fee structures are in place according to
Chapter 70.94 RCW. Local Assessments are used to pay the difference between program costs
and grant funds and fees collected.
• 131 Air Operating Permit Title V - federally mandated, fee based full cost recovery
• 132 Asbestos fee based full cost recovery
• 133 Source Registration - fee based full cost recovery
• 134 NOC/NOI/SEPA -partially fee based cost recovery
FIDUCIARY FUND TYPES:
Fiduciary funds account for assets held by the government in a trustee capacity or as an agent on
behalf of others.
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Agency Funds
These funds are used to account assets that the government holds on behalf of others in a custodial
capacity.
• 601 Air Operating Permit/Department of Ecology Oversight (AOP/ECY)
Used for assets held by Spokane Regional Clean Air Agency in a trustee capacity as the
agent for the WA State Department of Ecology (ECY). The fund was established in FY-10.
SRCAA includes an annual AOP/ECY program oversight fee, which is calculated by ECY,
on its annual billing to all Title V Air Operating Permit Sources. This fee is collected
annually by SRCAA and passed through to ECY.
B. Basis of Accounting and Measurement Focus
Financial statements are prepared using the cash basis of accounting and measurement focus.
Revenues are recognized when cash is received and expenditures are recognized when paid.
In accordance with state law, SRCAA also recognizes expenditures paid during twenty days after
the close of the fiscal year for claims incurred during the previous period.
C. Budgets
The SRCAA Board of Directors adopts an annual appropriated entity wide budget for all
anticipated resources and outlays for the fiscal period. The comprehensive budget document
summarizes, at the fund level, the operating budgets for the following funds:
• 001 General Fund
• 131 Air Operating Permit. Title V
• 132 Asbestos
• 133 Source Registration
• 134 NOC/NOI/SEPA
A single resolution containing all appropriations is approved by the Board of Directors. The
budget constitutes the legal authority for expenditures at that level. Annual appropriations lapse at
the fiscal period end.
Budgets for project specific funds are adopted by separate resolution identifying details regarding
the special purpose or funding source requirements. The budgets for the following funds have
been adopted by separate resolution:
• 104 VERPIII
• 129 Wood Smoke Reduction (State Grant)
Annual appropriated budgets are adopted on the same basis of accounting as used for financial
reporting.
The appropriated and actual expenditures for the legally adopted budgets were as follows:
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Fund/Department
Final Appropriation
Actual Expenditures
Variance
001- General Fund
$ 1,442,802.22
$ 1,056,750.64
$ 386,051.58
104- VERP III
$ 27,620.59
$ 16,783.25
$ 10,837.34
129 - Wood Smoke Reduction 16 & 17
$ 85,250.00
$ 81,818.68
$ 3,431.32
131 - Air Operating Permit Title V
$ 203,800.00
$ 192,798.59
$ 11,001.41
132 - Asbestos
$ 224,210.00
$ 202,716.00
$ 21,494.00
133 - Source Registration
$ 499,445.00
$ 499,445.00
$
134- NOC/NOI/SEPA
$ 201,720.00
$ 179,057.00
$ 22,663.00
Budgeted amounts are authorized to be transferred between programs; however, any revisions that
alter the total appropriation or that affect the number of authorized employee positions, salary
ranges, hours, or other conditions of employment, must be approved by the agency Board of
Directors.
SRCAA budget procedures are mandated by RCW 70.94.092. The steps in the budget process are as
follows:
1) No later than the May Board of Directors meeting, the Agency Executive Director submits a
proposed budget to the Board of Directors. This budget is based on priorities established by the
Executive Director and the Board and estimates provided by Agency Section Managers during
the preceding months, and balanced with revenue estimates made by the Agency Finance &
Human Resources Manager.
2) SRCAA Board of Directors conducts a public meeting on the proposed budget in May and/or
June.
3) SRCAA Board of Directors make adjustments to the proposed budget and conduct a public
hearing to adopt, by resolution, a final balanced budget no later than the fourth Monday in June.
4) Within 30 days of adoption, the final budget is available to the public.
5) Amending the Budget - When the SRCAA Board of Directors determine that it is in the best
interest of the Agency to increase or decrease appropriations, it may do so by resolution after
holding public hearings.
D. Cash and Investments
See Note 2, Deposits and Investments.
E. Capital Assets
Capital assets are assets with an initial individual cost of more than $2,000 and an estimated useful
life in excess of seven (7) years. Capital assets and inventory are recorded as capital expenditures
when purchased.
F. Compensated Absences
Compensated absences are absences for which employees may be paid, such as vacation,
compensatory leave, and sick leave. Payments are recognized as expenditures when paid.
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Vacation leave may be accumulated up to 360 hours. Upon separation from employment, the
employee receives payment for any unused vacation.
Sick leave may be accumulated indefinitely. Employees who terminate employment for any
reason other than retirement will not be compensated for unused sick leave. Sick leave is used on a
last in - first out basis. Upon retirement employees unused sick leave will be paid at the
employee's base rate of pay up to a maximum total of 975 hours as follows:
• Employees will be paid for 50% of hours accrued prior to November 1, 2007
• Employees will be paid for 25% of hours accrued on or after November 1, 2007
The accompanying Schedule of Liabilities includes an additional 1.45% to adjust for Medicare
taxes. At the end of fiscal year 2017, the total Compensated Absences Liability was $146,684.
G. Long-Term Debt
See Note 3, Debt Service Requirements.
H. Risk Management
Spokane Regional Clean Air Agency is a member of Enduris. Chapter 48.62 RCW provides the
exclusive source of local government entity authority to individually or jointly self-insure risks,
jointly purchase insurance or reinsurance, and to contract for risk management, claims, and
administrative services. Enduris was formed My 10, 1987 pursuant to the provisions of Chapter
48.62 RCW, Chapter 200-100 WAC, and Chapter 39.34 RCW. Two (2) counties and two (2)
cities in the State of Washington joined together by signing an interlocal governmental agreement
to fund their self-insured losses and jointly purchase insurance and administrative services. As of
August 31, 2017, there are 540 Enduris members representing a broad array of special purpose
districts throughout the state. Enduris provides property and liability coverage as well as risk
management services and other related administrative services.
Members make an annual contribution to fund Enduris and share in the self-insured retention of the
jointly purchased excess and/or reinsurance coverage. The self-insured retention is:
• $1,000,000 deductible on liability loss - the member is responsible for the first $1,000 of the
deductible amount of each claim, while Enduris is responsible for the remaining $999,000 on a
liability loss.
• $250,000 deductible on property loss - the member is responsible for the first $1,000 of the
deductible amount of each claim, while Enduris is responsible for the remaining $249,000 on a
properly loss.
• Enduris is responsible for the $4,000 deductible on boiler and machinery loss.
Enduris acquires reinsurance from unrelated insurance companies on a "per occurrence" basis to
cover all losses over the deductibles as shown on the policy maximum limits. Liability coverage is
for all lines of liability coverage including Public Official's Liability. The Property coverage is
written on an "all risk", blanket basis using current Statement of Values. The Property coverage
includes but is not limited to mobile equipment, boiler and machinery, electronic data processing
equipment, business interruption, course of construction and additions, property in transit, fine arts,
cyber and automobile physical damage to insured vehicles. Liability coverage limit is $20 million
per occurrence and property coverage limit is $1 billion per occurrence. Enduris offers crime
coverage up to a limit of $1 million per occurrence.
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Since Enduris is a cooperative program, there is a joint liability among the participating members.
The contract requires members to continue membership for a period of not less than one (1) year
and must give notice 60 days before terminating participation. The Master Agreement
(Intergovernmental Contract) is automatically renewed after the initial one (1) full fiscal year
commitment. Even after termination, a member is still responsible for contribution to Enduris for
any unresolved, unreported and in-process claims for the period they were a signatory to the
Master Agreement.
Enduris is fully funded by its member participants. Claims are filed by members with Enduris and
are administered in house.
A Board of Directors consisting of seven (7) board members governs Enduris. Its members elect
the Board and the positions are filled on a rotating basis. The Board meets quarterly and is
responsible for conducting the business affairs of Enduris.
I. Reserved Portion of Ending Cash and Investments
Beginning and Ending Cash and Investments is reported as reserved when it is subject to
restrictions on use imposed by external parties or due to internal commitments established by the
SRCAA Board of Directors. When expenditures that meet these restrictions are incurred, SRCAA
intends to use reserved resources first before using unreserved amounts.
The agency has the following reserve funds that have been established with resolutions by the
Board of Directors. These funds are reserved for the specific use indicated by the fund title.
Annual deposits for these funds are included in the general fund budget each year. While the
funding is included in the general fund budget process, specific resolutions for each fund
appropriation and expenditure are required as separate actions.
Fund Name
Amount Reserved
Reason for Restriction
006 Retirement Reserve
$ 76,748.23
Pay out of Annual and/or Sick Leave at retirement
007 Monitoring Equipment Reserve
$ 56,522.17
Replace Air Monitoring Equipment as needed
008 Vehicle Reserve
$ 55,221.36
Replace Vehicles as needed
009 Building Maintenance Reserve
$ 148,874.70
Maintain and Upgrade Facilities as needed
010 Information Technology Reserve
$ 28,000.00
Maintain and Upgrade IT as needed
011 Ozone Study Reserve
$ 50,000.00
Future Ozone study(s)
104VERP III
$ 10,837.34
Vehicle Emission Repair Program
Fee based programs are authorized under RCW 70.94.151, 70.94.152, 70.94.161 and 70.94.162.
The RCW details the work that can be charged to the programs. In addition, the RCW mandates
that fees collected under this authority must be used strictly for running that program. Therefore,
all year end fund balance is defined as reserved and is included in the next year's budget.
Fund Name
Amount Reserved
Reason for Restriction
131 Air Operating Permit
$
Fee based program RCW 70.94
132 Asbestos
$ 274,313.31
Fee based program RCW 70.94
133 Registration
$ 233,424.01
Fee based program RCW 70.94
134 NOC/NOI/SEPA
$
Fee based program RCW 70.94
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Unreserved Fund Balance
The fund balance in the following funds is unreserved and available for appropriation by resolution
and Board approval:
Fund Name
Amount
Comment
001 General Fund
$ 1,138,304.77
005 Project Reserve
$ 22,013.73
Unidentified projects that benefit the Agency
Note 2 - Deposits and Investments
SRCAA entered into an agreement with The Spokane County Treasurer for banking management
services. The Spokane County Treasurer acts as treasurer for all SRCAA deposits are invested as legally
prescribed in various financial institutions in the form of U.S. Government obligations, U.S. Government
agencies, certificates of deposit, savings accounts, bankers" acceptances, repurchase agreements,
municipal bonds, and the Washington State Treasurers Local Government Investment Pool. The
agreement also provides for accurate payment of banking fees for accounts administered by the Spokane
County Treasurer as the ex officio Treasurer for SRCAA.
It is the policy of Spokane County to safely invest public funds in accordance with governing statutes in
a manner which will provide the best investment return given; the Treasurer has a banking custodial duty
to return the principal to the entities when needed. Investments are made by designated personnel in
accordance with the Spokane County Treasurer's investment policy. The Treasurer's policy dictates that
all investment instruments other than certificates of deposit and County notes be transacted on the
delivery-versus-payment basis.
The County's deposits and certificates of deposit are held by banks that are designated as public
depositories in the state of Washington and fall under the scope of the state of Washington's Public
Deposit Protection Act. Public depositories must fully collateralize all uninsured public funds with
collateral held by a designated trustee.
Type of Investment
Cash Balance as of June BO, 2017
Spokane County Investment Pool
$2,133,506.24
Note 3 - Debt Service Requirements
SRCAA has no long-term debt.
Note 4 - Pension Plans
A. State Sponsored Pension Plans
All SRCAA full-time and qualifying part-time employees participate in the following statewide
retirement systems administered by the Washington State Department of Retirement Systems
(DRS), under cost-sharing, multiple-employer public employee defined benefit and defined
contribution retirement plans (PERS 2 and PERS 3).
The State Legislature establishes, and amends, laws pertaining to the creation and administration of
all public retirement systems.
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The Department of Retirement Systems, a department within the primary government of the State
of Washington, issues a publicly available comprehensive annual financial report (CAFR) that
includes financial statements and required supplementary information for each plan. The DRS
CAFR may be obtained by writing to:
Department of Retirement Systems
Communications Unit
P.O. Box 48380
Olympia, WA 98540-8380
Also, the DRS CAFR may be downloaded from the DRS website at www.drs.wa.gov.
At June 30, 2017 (the measurement date of the plans), SRCAA proportionate share of the
collective net pension liabilities, as reported on the Schedule 09, was as follows:
Plan Type
Employer
Contribution
FY17 Ending Net
Pension Liability
Allocation %
Liability (Asset)
PERS 1
$ 56,357
$ 4,745,078,000
0.009369%
$ 444,566
PERS2/3
$ 73,607
$ 3,474,522,000
0.012051%
$ 418,715
Note 5 - Other Disclosures
Significant transactions with related parties.
There are three elected officials on the SRCAA Board of Directors that are in positions to influence
budgetary and financial decisions and policies for other entities. They may also be appointed to various
committees and regional groups. These members would be considered related parties. There have been
no significant transactions with related parties.
Extraordinary events.
Two insurance claims were filed in FY17 with Enduris Risk Management.
1) Vandalism occurred to the Air Monitoring Equipment at the Sunset Elementary (Airway Heights)
monitoring site. Total repair costs $2,110.56 (includes $1,000 deductible).
2) Extensive water damage occurred to the Executive Directors office caused by an Ice Dam build up
during the winter months. Total repair costs $16,162.50 (includes $1,000 deductible).
Contingencies and litigations.
SRCAA goes through the appeal process for any Notice of Violation Appeals that are filed with the
Pollution Control Hearings Board by the violators. Mitigation is generally successful; where both parties
agree on a settlement prior to the hearing.
Self-Insurance.
SRCAA does not self-insure.
Other
There are no events after the end of the period to report.
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SRC A A has no joint ventures.
There is no reason to doubt the long-term continuation of SRC A A as a municipal corporation.
There are no significant commitments or obligations on SRC A A financial resources that are not disclosed
in other sections.
Cost Recovery Programs
Regulations and Fee Schedules are in place for service fees for the following Funds: 132 Asbestos, 133
Source Registration, and 134 NOC/NOI/SEPA. Fees collected are to be used to cover the cost of each
program. Any fees collected exceeding the program cost will be a reserve fund balance for that program
and included in the budget the following year to cover the cost of the program. Annual review of
program costs and revenue will be conducted by staff and fee adjustments will be suggested to the Board
of Directors as necessary. Changes in fees must follow the standard public notice and public hearing
protocol and Board approval prior to an effective date.
Fund 131 Air Operating Permit Title V is managed to meet requirements in Chapter 173-401 WAC. This
includes permitting, inspections, compliance issues, and annual fees as well as many other specific
elements. The program is full cost recovery with Spokane Regional Clean Air Agency Regulations and
fee structure in place. Total program costs are billed annually to the affected industrial facilities. The
cost of this program fluctuates each year depending on staff time, on new permits, permit renewals,
compliance, and industry upgrades and equipment changes. The level of production at facilities is also a
factor because of the changes in emissions with every increase or decrease in operations.
On-Line Electronic Asbestos
Notice of Intent for Asbestos projects continue to be filed through the Agency's web site. Contractors or
the public can log on to the site and complete the NOI and make payment through the on-line payment
option. The information is imported into an agency data base. Asbestos project notices are also accepted
in the office or by mail.
FY-17 Staffing
SRCAA changed a Part Time Administrative Assistant position to Full Time within the annual budget
approved with Resolution 17-02 bringing the total staff including the Executive Director to 19 full time
employees.
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MCAG #: 1026
SPOKANE REGIONAL CLEAN AIR AGENCY ANNUAL REPORT
NOTES TO THE FINANCIAL STATEMENTS
FOR FISCAL YEAR ENDED JUNE 30, 2016
NOTE 1 - SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES
The Spokane Regional Clean Air Agency (SRCAA) was incorporated on January 1, 1969 and operates under the laws of
the state of Washington applicable to Air Pollution Control Agencies. SRCAA is a special purpose district government
with the duty to administer federal and state air quality laws and federal, state, and local air quality regulations in Spokane
County.
• SRCAA operates an air monitoring network which gathers data and reports air quality and the level of pollution for
PM2.5, PM10, and Ozone to the public on an hourly basis.
• Provides education and outreach to the public through direct contact at schools, local events, and social media.
• Issues air permits to businesses that create air emissions such as auto body painting, gas stations, large industrial
facilities, and others.
• Provides Air Quality maintenance planning and monitoring to ensure continued attainment of the Federal Air
Quality Standards for Spokane County.
• Serve the public by responding to complaints and enforcing State, Federal, and Local Air Quality regulations
according to Chapter 70.94.100 RCW Air Pollution Control Authority.
SRCAA reports financial activity in accordance with the Cash Basis Budgeting Accounting and Reporting System (BARS)
Manual prescribed by the State Auditor's Office under the authority of Washington State law, Chapter 43.09 RCW. This
manual prescribes a financial reporting framework that differs from generally accepted accounting principles (GAAP) in
the following manner:
• Financial transactions are recognized on a cash basis of accounting as described below.
• Component units are required to be disclosed, but are not included in the financial statements.
• Government-wide statements, as defined in GAAP, are not presented.
• All funds are presented rather than a focus on major funds.
• The Schedule of Liabilities is required to be presented with the financial statements as supplementary information.
• Supplementary information required by GAAP is not presented.
• Ending balances are not presented using the classifications defined in GAAP.
A. Fund Accounting
Financial transactions of the government are reported in individual funds. Each fund uses a separate set of self-
balancing accounts that comprises its cash and investments, revenues and expenditures. The government's
resources are allocated to and accounted for in individual funds depending on their intended purpose. Each fund is
reported as a separate column in the financial statements. The following fund types are used:
GOVERNMENTAL FUND TYPES:
General Fund 001
This fund is the primary operating fund of SRCAA. It accounts for all financial resources except those required or
elected to be accounted for in another fund.
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MCAG #: 1026
SPOKANE REGIONAL CLEAN AIR AGENCY ANNUAL REPORT
NOTES TO THE FINANCIAL STATEMENTS
FOR FISCAL YEAR ENDED JUNE 30, 2016
The following funds have been established by Resolution and adopted by the Board of Directors as designated
reserves that have been elected to be accounted for in separate funds. These funds roll-up into the general fund for
reporting purposes. A Resolution must be approved by the Board of Directors to appropriate expenditures or
transfer any portion of the fund balance to another fund.
Fund 002 - Petty Cash
Fund 005 - Project Reserve
Fund 006 - Retirement Reserve
Fund 007 - Equipment Reserve
Fund 008 - Vehicle Reserve
Fund 009 - Building Maintenance Reserve
Fund 010 - Information Technology (IT) Reserve
Fund 011- Ozone Study Reserve (established with Resolution 16-04 April 2016)
Special Revenue Funds
These funds account for specific revenue sources that are restricted or committed to expenditures for specified
purposes of the government. Active Special Revenue Funds in FY-16 include the following:
Fund 104 - VERP III
Fund 129 - State Wood Smoke Reduction (Grant)
The following funds account for operations that provide goods or services to the general public and are supported
primarily through user charges. Fee structures are in place according to Chapter 70.94.RCW. Local Assessments
are used to pay the difference between program costs and fees collected.
Fund 131 - Air Operating Permit Title V - federally mandated, fee based full cost recovery
Fund 132 - Asbestos - fee based full cost recovery
Fund 133 - Source Registration - fee based full cost recovery
Fund 134 - NOC/NOI/SEPA -partially fee based cost recovery
Debt Service Funds
These funds account for the financial resources that are restricted, committed or assigned to expenditures for
principal, interest and related costs on general long-term debt.
Currently SRCAA has no long-term debt.
FIDUCIARY FUNDS TYPES
Fiduciary funds account for assets held by the government in a trustee capacity or as an agency on behalf of others.
Agency Funds
These funds are used to account for assets that the government holds on behalf of others in a custodial capacity.
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#: 1026
SPOKANE REGIONAL CLEAN AIR AGENCY ANNUAL REPORT
NOTES TO THE FINANCIAL STATEMENTS
FOR FISCAL YEAR ENDED JUNE 30, 2016
Fund 601 - Air Operating Permit/Department of Ecology Oversight (AOP/ECY) accounts for assets
held by Spokane Regional Clean Air Agency in a trustee capacity as the agent for the State
Department of Ecology. The fund was established in FY-10. SRC A A includes an annual
AOP/ECY program oversight fee, which is calculated by Ecology, on its annual billing to all Title
V Air Operating Permit sources. This fee is collected by SRC A A and passed-thru to Ecology in
two payments, March and June each year.
Basis of Accounting and Measurement Focus
Financial statements are prepared using the cash basis of accounting and measurement focus. Revenues are
recognized when cash is received and expenditures are recognized when paid.
In accordance with state law, SRCAA also recognizes expenditures paid during twenty days after the close of the
fiscal year for claims incurred during the previous period.
Budgets
The SRCAA Board of Directors adopts an annual appropriated entity wide budget for all anticipated resources and
outlays for the fiscal period. The comprehensive budget document summarizes, at the fund level, the operating
budgets for the following funds:
• 001 General Fund
• 131 Air Operating Permit Title V
• 132 Asbestos
• 133 Source Registration
• 134 NOC/NOI/SEPA
A single resolution containing all appropriations is approved by the Board of Directors. The budget constitutes the
legal authority for expenditures at that level. Annual appropriations lapse at the fiscal period end.
Budgets for project specific funds are adopted by separate resolution identifying details regarding the special
purpose or funding source requirements. The budgets for the following funds have been adopted by separate
resolution:
• 104 VERP III
• 129 State Wood Smoke Reduction (Grant)
Annual appropriated budgets are adopted on the same basis of accounting as used for financial reporting.
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#: 1026
SPOKANE REGIONAL CLEAN AIR AGENCY ANNUAL REPORT
NOTES TO THE FINANCIAL STATEMENTS
FOR FISCAL YEAR ENDED JUNE 30, 2016
The appropriated and actual expenditures for the legally adopted budget is as follows:
Fund
Final Apprepriation
Actual Ex pe redit u re s
Variance
001 - General Fund Expense
$1,240,738.00
$1,099,568.49
$141,169.51
104 - VERP III
$27,290.32
$19,669.73
$7,620.59
129 - State Wood Smoke Reduction
$115,000.00
$50,750.00
$64,250.00
131 - Air Operating Permit Title V
$181,560.00
$175,763.61
$5,796.39
132 - Asbestos
$249,575.00
$234,848.32
$14,726.68
133 - Source Registration
$527,076.00
$374,858.02
$152,217.98
134 - NOC/NOI/SEPA
$251,600.00
$162,215.43
$89,384.57
$2,592,839.32
$2,117,673.60
$475,165.72
Budgeted amounts are authorized to be transferred between programs; however, any revisions that alter the total
appropriation, or that affect the number of authorized employee positions, salary ranges, hours, or other conditions
of employment, must be approved by the agency Board of Directors.
The Agency's budget procedures are mandated by RCW 70.94.092. The steps in the budget process are as follows:
1) Prior to the May Board of Directors meeting, the Agency Executive Director submits a proposed budget to
the Board of Directors. This budget is based on priorities established by the Executive Director and the
Board and estimates provided by Agency Section Managers during the preceding months, and balanced
with revenue estimates made by the Agency Finance & Personnel Administrator.
2) The Agency Board of Directors conducts public meetings on the proposed budget in May and/or June.
3) The Agency Board of Directors make adjustments to the proposed budget and conduct a public hearing to
adopt, by resolution, a final balanced budget no later than the fourth Monday in June.
4) Within 30 days of adoption, the final budget is available to the public.
5) Amending the Budget - When the Agency Board of Directors determine that it is in the best interest of the
Agency to increase or decrease appropriations, it may do so by resolution after holding public hearings.
Cash and Investments
See Note 2, Deposits and Investments.
Capital Assets
Capital assets are long-lived assets of the SRC A A and are recorded as expenditures when purchased. Capital assets
of the Agency consist of machinery and equipment with a purchase price of $2,000 or greater and a useful life of
seven (7) or more years. Capital assets are recorded as expenditures when purchased.
A summary of changes in the general fixed assets follows:
Washington State Auditor's Office
Page 30
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MCAG #: 1026
SPOKANE REGIONAL CLEAN AIR AGENCY ANNUAL REPORT
NOTES TO THE FINANCIAL STATEMENTS
FOR FISCAL YEAR ENDED JUNE 30, 2016
Balance My 1,2015 $ 1,276,133
Additions $ 55,555
Deletions $ 17,738
Balance June 30, 2016 $ 1,313,950
F. Compensated Absences
Vacation leave may be accumulated up to 360 hours, and is payable upon resignation, retirement, or death. At June
30, 2016 total accumulated leave liability (sick and vacation) was valued at $145,116 also shown on Schedule 9.
This represents a $3,633 increase of the June 30, 2015 leave liability.
Employees may accrue an unlimited number of sick leave hours. Upon retirement employees unused sick leave
will be paid at the employees base rate of pay up to a maximum total of 975 hours as follows:
• Employees will be paid for 50% of hours accrued prior to November 1, 2007 and will be paid for 25% of hours
accrued on or after November 1, 2007. Sick leave is used on a last in first out basis.
• Employees who terminate employment for any reason other than retirement will not be compensated for unused
sick leave.
G. Long-Term Debt See Note 3, Debt Service Requirements.
H. Risk Management
SRCAA is a member of Enduris. Chapter 48.62 RCW provides the exclusive source of local government entity
authority to individually or jointly self-insure risks, jointly purchase insurance or reinsurance, and to contract for
risk management, claims, and administrative services. Enduris was formed July 10, 1987 pursuant to the
provisions of Chapter 48.62 RCW, Chapter 200-100 WAC, and Chapter 39.34 RCW. Two (2) counties and two
(2) cities in the State of Washington joined together by signing an interlocal governmental agreement to fund their
self-insured losses and jointly purchase insurance and administrative services. As of August 31, 2016, there are
507 Enduris members representing a broad array of special purpose districts throughout the state. Enduris
provides properly and liability coverage as well as risk management services and other related administrative
services.
Members make an annual contribution to fund Enduris and share in the self-insured retention of the jointly
purchased excess and/or reinsurance coverage. The self-insured retention is:
• $1,000,000 deductible on liability loss - the member is responsible for the first $1,000 of the deductible
amount of each claim, while Enduris is responsible for the remaining $999,000 on a liability loss.
• $250,000 deductible on properly loss - the member is responsible for the first $1,000 of the deductible
amount of each claim, while Enduris is responsible for the remaining $249,000 on a property loss.
• Enduris is responsible for the $4,000 deductible on boiler and machinery loss.
Washington State Auditor's Office
Page 31
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MCAG #: 1026
SPOKANE REGIONAL CLEAN AIR AGENCY ANNUAL REPORT
NOTES TO THE FINANCIAL STATEMENTS
FOR FISCAL YEAR ENDED JUNE 30, 2016
Enduris acquires reinsurance from unrelated insurance companies on a "per occurrence" basis to cover all losses
over the deductibles as shown on the policy maximum limits. Liability coverage is for all lines of liability
coverage including Public Official's Liability. The Property coverage is written on an "all risk", blanket basis
using current Statement of Values. The Property coverage includes but is not limited to mobile equipment, boiler
and machinery, electronic data processing equipment, business interruption, course of construction and additions,
properly in transit, fine arts, and automobile physical damage to insured vehicles. Liability coverage limit is $10
million per occurrence and property coverage limit is $1 billion per occurrence. Enduris offers crime coverage up
to a limit of $1 million per occurrence.
Since Enduris is a cooperative program, there is a joint liability among the participating members.
The contract requires members to continue membership for a period of not less than one (1) year and must give
notice 60 days before terminating participation. The Master Agreement (Intergovernmental Contract) is
automatically renewed after the initial one (1) full fiscal year commitment. Even after termination, a member is
still responsible for contribution to Enduris for any unresolved, unreported and in-process claims for the period
they were a signatory to the Master Agreement.
Enduris is fully funded by its member participants. Claims are filed by members with Enduris and are
administered in house.
A Board of Directors consisting of seven (7) board members governs Enduris. Its members elect the Board and
the positions are filled on a rotating basis. The Board meets quarterly and is responsible for conducting the
business affairs of Enduris.
Enduris Annual Financial Statement and reports may be found at their web site www.enduris.us.
I. Reserved Portion of Ending Cash and Investments
Beginning and Ending Cash and Investments is reported as reserved when it is subject to restrictions on use imposed
by external parties or due to internal commitments established by the SRC A A Board of Directors. When
expenditures that meet these restrictions are incurred, the SRC A A intends to use reserved resources first before
using unreserved amounts. Reservations of Ending Cash and Investments are listed below:
The agency has the following reserve funds that have been established with resolutions by the Board of Directors.
These funds are reserved for the specific use indicated by the fund title. Annual deposits for these funds are included
in the general fund budget each year. While the funding is included in the general fund budget process, specific
resolutions for each fund appropriation and expenditure are required as separate actions.
• Fund 006 Retirement Reserve
Purpose: to pay annual leave and sick leave at retirement
June 30, 2016 balance: $97,527
• Fund 007 Equipment Reserve
Purpose: to replace monitoring equipment
June 30, 2016 balance: $29,200
• Fund 008 Vehicle Reserve
Purpose: to replace vehicles as needed
June 30, 2016 balance: $59,629
• Fund 009 Building Maintenance Reserve
Purpose: to maintain and upgrade the building as needed
Washington State Auditor's Office
Page 32
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MCAG #: 1026
SPOKANE REGIONAL CLEAN AIR AGENCY ANNUAL REPORT
NOTES TO THE FINANCIAL STATEMENTS
FOR FISCAL YEAR ENDED JUNE 30, 2016
June 30, 2016 balance: $48,875
• Fund 010 Information Technology (IT) Reserve
Purpose: to upgrade and stay current with technology
June 30, 2016 balance: $14,000
• Fund 011 Ozone Study Reserve
Purpose: to fund an ozone study in the future
June 30, 2016 balance: $0.00
• Fund 104 VERP III (Vehicle Emission Repair Program)
Fund 104 VERP III was established in 2001 as a program to reduce vehicle emissions and is a
Vehicle Emission Repair Program. It was originally established as a Supplemental Environmental
Project to achieve transportation related emission reductions. It is a joint program operated under a
Memorandum of Understanding between Spokane Clean Air, State Department of Ecology (ECY)
and Spokane Neighborhood Action Partners (SNAP). Funding sources have varied over the years
from large specific enforcement agreements, to state transportation emission reduction grants.
Since 2010 it has been funded with appropriations from Spokane Clean Air Project Reserve Fund
005. The funds are appropriated for the specific use of continuing the VERP program and thereafter
reserved and carried forward each year.
June 30, 2016 balance: $7,620.
Fee based programs are authorized under RCW 70.94.151, 70.94.152, 70.94.161 and 70.94.162. The RCW details
the work that can be charged to the programs. In addition, the RCW mandates that fees collected under this authority
must be used strictly for running that program. Therefore, all year end fund balance is defined as reserved and is
included in the next year's budget.
• Fund 131 Air Operating Permit Title V
June 30, 2016 balance: $0.00
• Fund 132 Asbestos
June 30, 2016 balance: $193,802
• Fund 133 Source Registration
June 30, 2016 balance: $231,148
• Fund 134 NOC/NOI/SEPA balance: $0.00
Unreserved Fund Balance
The fund balance in the following funds is unreserved and available for appropriation by resolution and Board
approval:
• Fund 001 General Fund
June 30, 2016 balance: $1,376,111.32
• Fund 005 Project Reserve
Purpose: Unidentified unfunded projects or purchases that benefit Spokane County Air Quality
June 30, 2016 balance: $2,764
NOTE 2 - DEPOSITS AND INVESTMENTS
A. Deposits
SRCAA entered into new agreement with The Spokane County Treasurer for banking management services in June of 2016.
The Spokane County Treasurer acts as treasurer for all SRCAA deposits are invested as legally prescribed in various
Washington State Auditor's Office
Page 33
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MCAG #: 1026
SPOKANE REGIONAL CLEAN AIR AGENCY ANNUAL REPORT
NOTES TO THE FINANCIAL STATEMENTS
FOR FISCAL YEAR ENDED JUNE 30, 2016
financial institutions in the form of U.S. Government obligations, U.S. Government agencies, certificates of deposit, savings
accounts, bankers' acceptances, repurchase agreements, municipal bonds, and the Washington State Treasurers Local
Government Investment Pool. The agreement also provides for accurate payment of banking fees for accounts administered
by the Spokane County Treasurer as the ex officio Treasurer for SRC A A.
B. Investments
It is the policy of Spokane County to safely invest public funds in accordance with governing statutes in a manner which
will provide the best investment return given; the Treasurer has a banking custodial duty to return the principal to the entities
when needed. Investments are made by designated personnel in accordance with the Spokane County Treasurer's
investment policy. The Treasurer's policy dictates that all investment instruments other than certificates of deposit and
County notes be transacted on the delivery-versus-payment basis.
The County's deposits and certificates of deposit are held by banks that are designated as public depositories in the state of
Washington and fall under the scope of the state of Washington's Public Deposit Protection Act. Public depositories must
fully collateralize all uninsured public funds with collateral held by a designated trustee.
As of June 30, 2016, the Agency's cash balance invested in the SCIP was $2,060,878. This amount is stated at cost.
NOTE 3 - LONG-TERM DEBT
SRC A A has no long-term debt.
NOTE 4 - STATE SPONSORED PENSION PLANS
A. State Sponsored Pension Plans
All Spokane Regional Clean Air Agency full-time and qualifying part-time employees participate in the following statewide
retirement systems administered by the Washington State Department of Retirement Systems (DRS), under cost-sharing,
multiple-employer public employee defined benefit and defined contribution retirement plans (PERS 2 and PERS 3).
The state Legislature establishes, and amends, laws pertaining to the creation and administration of all public retirement
systems.
The Department of Retirement Systems, a department within the primary government of the State of Washington, issues a
publicly available comprehensive annual financial report (CAFR) that includes financial statements and required
supplementary information for each plan. The DRS CAFR may be obtained by writing to:
Department of Retirement Systems
Communications Unit
P.O. Box 48380
Olympia, WA 98540-8380
The DRS CAFR may also be downloaded from the DRS website at www.drs.wa.gov.
At June 30,2016 (the measurement date of the plans), SRCAA's proportionate share of the collective net pension
liabilities*, as reported on Schedule 9, was as follows:
Washington State Auditor's Office
Page 34
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MCAG #: 1026
SPOKANE REGIONAL CLEAN AIR AGENCY ANNUAL REPORT
NOTES TO THE FINANCIAL STATEMENTS
FOR FISCAL YEAR ENDED JUNE 30, 2016
Plan Type
Employer
Contribution
FY16 Ending Net
Pension Liability
Allocation %
Liability f Asset)
PERS 1
$ 53,635
$ 5,370,471,000
0.009458%
$ 507,939
PERS 2/3
$ 70,053
$ 5,034,921,000
0.012135%
$ 610,988
* For DRS sponsored plans, the allocation percentage and collective liability for each plan is available at www.clrs.wa.gov.
NOTE 5 -OTHER DISCLOSURES
Significant transactions with related parties.
There are three elected officials on the SRC A A Board of Directors that are in positions to influence budgetary and financial
decisions and policies for other entities. They may also be appointed to various committees and regional groups. These
members would be considered related parties. There have been no significant transactions with related parties.
There were no extraordinary events this period.
Contingencies and litigations.
SRC A A goes through the appeal process for any Notice of Violation Appeals that are filed with the Pollution Control
Hearings Board by the violators. Mitigation is generally successful; where both parties agree on a settlement prior to the
hearing.
Marijuana producers may file a declaratory action relating to the application of RCW 70.94.640 to marijuana grow
operations.
Self-Insurance. SRC A A does not self-insure.
There are no events after the end of the period to report.
SRC A A has no joint ventures.
There is no reason to doubt the long-term continuation of SRCAA as a municipal corporation.
There are no significant commitments or obligations on SRCAA financial resources that are not disclosed in other sections.
Other Items
Cost Recovery Programs
Regulations and Fee Schedules are in place for service fees for the following Funds: 132 Asbestos, 133 Source
Registration, and 134 NOC/NOI/SEPA. Fees collected are to be used to cover the cost of each program. Any fees
collected exceeding the program cost will be a reserve fund balance for that program and included in the budget the
following year to cover the cost of the program. Annual review of program costs and revenue will be conducted by
staff and fee adjustments will be suggested to the Board of Directors as necessary. Changes in fees must follow the
standard public notice and public hearing protocol and Board approval prior to an effective date.
Fund 131 Air Operating Permit Title V is managed to meet requirements in Chapter 173-401 WAC. This includes
permitting, inspections, compliance issues, and annual fees as well as many other specific elements. The program
is full cost recovery with Spokane Regional Clean Air Agency Regulations and fee structure in place. Total program
Washington State Auditor's Office
Page 35
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MCAG #: 1026
SPOKANE REGIONAL CLEAN AIR AGENCY ANNUAL REPORT
NOTES TO THE FINANCIAL STATEMENTS
FOR FISCAL YEAR ENDED JUNE 30, 2016
costs are billed annually to the affected industrial facilities. The cost of this program fluctuates each year depending
on staff time, on new permits, permit renewals, compliance, and industry upgrades and equipment changes. The
level of production at facilities is also a factor because of the changes in emissions with every increase or decrease
in operations.
ON-LINE Electronic Asbestos Notice of Intent for Asbestos projects continue to be filed thru our web site.
Contractors or the public can log on to the site and complete the NOI and make payment thru the on-line payment
option. The information is imported into an agency data base. Asbestos project notices are also accepted in the
office or by mail.
SRCAA accepts credit card payments for fees for services On-Line only (SRCAA does not accept face to face or
over the phone credit card transactions) there is a 3.8% fee charged to the user to help off-set the banking fees
assessed for each transaction.
The funds are transferred electronically into the County Bank account daily. Standard cash receipts are prepared at
SRCAA and submitted to the County Treasurer's office where the funds are then deposited into SRCAA's account.
It has been determined that the credit card banking fees not recovered are a cost of doing business.
SRCAA declared a state of emergency pursuant to SRCAA Regulation I Article IX Asbestos Control Standards,
Section 9.04.A.7.i. The declaration was issued due to a severe windstorm on November 17, 2015 that caused
widespread damage to structures in Spokane County. SRCAA issued an Emergency Order whereby the SRCAA
Regulation I, Section 10.09 and parts of SRCAA's fee schedule and waiting periods would be waived, if it was
demonstrated to SRCAA's satisfaction that the structure was damaged by the windstorm on November 17, 2015.
The Order was issued on November 19, 2015 with an end date of March 31, 2016 which was later extended to
December 31, 2016.
A total of $10,200 asbestos fess where waived under this Emergency Order in FY-16 for thirty-four (34) separate
Notice of Intent for Asbestos Projects or Demolition permits.
Agency Building Maintenance
Resolution 15-18 was approved My 2, 2015 appropriating $75,000 Unreserved General Fund Balance to replace
the entire roof on the Agency office building located at 3104 E Augusta Ave, Spokane. The roof replacement was
necessary to preserve the integrity of the structure and ensure its longevity.
Resolution 15-21 was approved September 3, 2015 appropriating $28,000 Unreserved General Fund Balance to
install a fall protection system that meets required safety standards on the roof at 3104 E Augusta Ave, Spokane.
The roof of the building is a primary monitoring site where various equipment is installed and requires regular
maintenance by staff. The equipment measures and monitors the air quality which is then reported to public and
the data is used in EPA reporting.
FY-16 Staffing
SRCAA added one new position a Rule Writer/SIP Planner within the annual budget approved with Resolution
15-14 bringing the total staff of 18.8 employees; eighteen full time and one person working 80%.
Washington State Auditor's Office
Page 36
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Spokane Regional Clean Air Agency
Schedule of Liabilities
For the Year Ended June 30, 2017
Beginning
ID. No. Description Due Date Balance Additions Reductions Ending Balance
Revenue and Other (non G.O.) Debt/Liabilities
264.30 PERS 1 - State Sponsored Pension 507,939 - 63,373 444,566
Plan
264.30 PERS 2/3 - State Sponsored Pension 610,988 - 192,273 418,715
Plan
259.12 Compensated Absences 145,116 1,568 - 146,684
Total Revenue and Other (non G.O.) 1,264,043 1,568 255,646 1,009,965
Debt/Liabilities:
Total Liabilities: 1,264,043 1,568 255,646 1,009,965
Washington State Auditor's Office
Page 3 7
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Spokane Regional Clean Air Agency
Schedule of Liabilities
For the Year Ended June 30, 2016
Beginning
ID. No. Description Due Date Balance Additions Reductions Ending Balance
Revenue and Other (non G.O.) Debt/Liabilities
259.12 Compensated absences 141,483 3,633 - 145,116
264.30 Pension Plan PERS 1 519,013 - 11,074 507,939
264.30 Pension Plan PERS 2 & 3 457,959 153,029 - 610,988
Total Revenue and Other (non G.O.) 1,118,455 156,662 11,074 1,264,043
Debt/Liabilities:
Total Liabilities: 1,118,455 156,662 11,074 1,264,043
Washington State Auditor's Office
Page 38
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ABOUT THE STATE AUDITOR'S OFFICE
The State Auditor's Office is established in the state's Constitution and is part of the executive
branch of state government. The State Auditor is elected by the citizens of Washington and serves
four-year terms.
We work with our audit clients and citizens to achieve our vision of government that works for
citizens, by helping governments work better, cost less, deliver higher value, and earn greater
public trust.
In fulfilling our mission to hold state and local governments accountable for the use of public
resources, we also hold ourselves accountable by continually improving our audit quality and
operational efficiency and developing highly engaged and committed employees.
As an elected agency, the State Auditor's Office has the independence necessary to objectively
perform audits and investigations. Our audits are designed to comply with professional standards
as well as to satisfy the requirements of federal, state, and local laws.
Our audits look at financial information and compliance with state, federal and local laws on the
part of all local governments, including schools, and all state agencies, including institutions of
higher education. In addition, we conduct performance audits of state agencies and local
governments as well as fraud, state whistleblower and citizen hotline investigations.
The results of our work are widely distributed through a variety of reports, which are available on
our website and through our free, electronic subscription service.
We take our role as partners in accountability seriously, and provide training and technical
assistance to governments, and have an extensive quality assurance program.
Contact information for the State Auditor's Office
Public Records requests
PublicRecords(a>sao. wa. gov
Main telephone
(360) 902-0370
Toll-free Citizen Hotline
(866) 902-3900
Website
www. sao. wa. gov
Washington State Auditor's Office
Page 39
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Fund
Account
Title
Trans
Date
Trans Type
131 300 340
345
17 00 00 41
AOP
Permit
Fees
737
11/17/2016
Tr Rec
131 300 340
345
17 00 00 41
AOP
Permit
Fees
737
11/17/2016
Tr Rec
131 300 340
345
17 00 00 41
AOP
Permit
Fees
737
11/17/2016
Tr Rec
131 300 340
345
17 00 00 41
AOP
Permit
Fees
741
11/18/2016
Tr Rec
131 300 340
345
17 00 00 41
AOP
Permit
Fees
741
11/18/2016
Tr Rec
131 300 340
345
17 00 00 41
AOP
Permit
Fees
741
11/18/2016
Tr Rec
131 300 340
345
17 00 00 41
AOP
Permit
Fees
795
11/22/2016
Tr Rec
131 300 340
345
17 00 00 41
AOP
Permit
Fees
795
11/22/2016
Tr Rec
131 300 340
345
17 00 00 41
AOP
Permit
Fees
795
11/22/2016
Tr Rec
131 300 340
345
17 00 00 41
AOP
Permit
Fees
796
11/23/2016
Tr Rec
131 300 340
345
17 00 00 41
AOP
Permit
Fees
796
11/23/2016
Tr Rec
131 300 340
345
17 00 00 41
AOP
Permit
Fees
796
11/23/2016
Tr Rec
131 300 340
345
17 00 00 41
AOP
Permit
Fees
799
11/28/2016
Tr Rec
131 300 340
345
17 00 00 41
AOP
Permit
Fees
799
11/28/2016
Tr Rec
131 300 340
345
17 00 00 41
AOP
Permit
Fees
799
11/28/2016
Tr Rec
131 300 340
345
17 00 00 41
AOP
Permit
Fees
800
11/28/2016
Tr Rec
131 300 340
345
17 00 00 41
AOP
Permit
Fees
800
11/28/2016
Tr Rec
131 300 340
345
17 00 00 41
AOP
Permit
Fees
800
11/28/2016
Tr Rec
131 300 340
345
17 00 00 41
AOP
Permit
Fees
806
11/30/2016
Tr Rec
131 300 340
345
17 00 00 41
AOP
Permit
Fees
806
11/30/2016
Tr Rec
131 300 340
345
17 00 00 41
AOP
Permit
Fees
806
11/30/2016
Tr Rec
131 300 340
345
17 00 00 41
AOP
Permit
Fees
936
12/20/2016
Tr Rec
131 300 340
345
17 00 00 41
AOP
Permit
Fees
936
12/20/2016
Tr Rec
131 300 340
345
17 00 00 41
AOP
Permit
Fees
936
12/20/2016
Tr Rec
131 300 340
345
17 00 00 41
AOP
Permit
Fees
941
12/23/2016
Tr Rec
131 300 340
345
17 00 00 41
AOP
Permit
Fees
941
12/23/2016
Tr Rec
131 300 340
345
17 00 00 41
AOP
Permit
Fees
941
12/23/2016
Tr Rec
131 300 340
345
17 00 00 41
AOP
Permit
Fees
2454
6/8/2017
Tr Rec
131 300 340
368
50 00 00 31
Local Assessment Funding AOP
2659
6/30/2017
Adjustmt
-------
Vendor
Melcher Manufacturing
Melcher Manufacturing
Melcher Manufacturing
Transcanadas Gtn System
Transcanadas Gtn System
Transcanadas Gtn System
Fiber Tech Industries Inc
Fiber Tech Industries Inc
Fiber Tech Industries Inc
Kaiser Aluminum Washington LLC
Kaiser Aluminum Washington LLC
Kaiser Aluminum Washington LLC
Northside Landfill
Northside Landfill
Northside Landfill
Spokane Regional Solid Waste System
Spokane Regional Solid Waste System
Spokane Regional Solid Waste System
Inland Empire Paper Company
Inland Empire Paper Company
Inland Empire Paper Company
Haakon Industries
Haakon Industries
Haakon Industries
Mutual Materials Company
Mutual Materials Company
Mutual Materials Company
Irs Environmental
Ncm Contracting Group LP
Amount Remark
4,113.56
3,000.00
295.22
3,000.00
9.785.18
6.674.19
3,000.00
1,310.80
3,391.62
16,521.91
27,927.00
3,000.00
3,000.00
157.76
10,960.71
3,000.00
24,304.32
12,370.75
6,967.48
7,990.08
3,000.00
3,000.00
1,145.50
2,680.96
3,000.00
7,320.18
4,846.78
9.5
17,025.09 Funding Adjustment For AOP Program
192,798.59
-------
Fund
Account
Title
Trans
Date Bank Acct
Check #
131 300 430
553 70 43 00 41
AOP Travel/Training
497
10/4/2016
1648
131 300 430
553 70 43 00 41
AOP Travel/Training
2046
4/5/2017
10080
131 300 430
553 70 43 00 41
AOP Travel/Training
2555
6/27/2017
10225
131300 516
553 70 11 00 41
AOPSala
ies
19
7/15/2016
131300 516
553 70 11 00 41
AOPSala
ies
20
7/15/2016
131300 516
553 70 11 00 41
AOPSala
ies
21
7/15/2016
131300 516
553 70 11 00 41
AOPSala
ies
23
7/15/2016
131300 516
553 70 11 00 41
AOPSala
ies
27
7/15/2016
131300 516
553 70 11 00 41
AOPSala
ies
32
7/15/2016
131300 516
553 70 11 00 41
AOPSala
ies
33
7/15/2016
131300 516
553 70 11 00 41
AOPSala
ies
37
7/15/2016
1480
131300 516
553 70 11 00 41
AOPSala
ies
38
7/15/2016
1481
131300 516
553 70 11 00 41
AOPSala
ies
38
7/15/2016
1481
131300 516
553 70 11 00 41
AOPSala
ies
39
7/15/2016
1482
131300 516
553 70 11 00 41
AOPSala
ies
39
7/15/2016
1482
131300 516
553 70 11 00 41
AOPSala
ies
39
7/15/2016
1482
131300 516
553 70 11 00 41
AOPSala
ies
40
7/15/2016
1483
131300 516
553 70 11 00 41
AOPSala
ies
41
7/15/2016
1484
131300 516
553 70 11 00 41
AOPSala
ies
102
7/29/2016
131300 516
553 70 11 00 41
AOPSala
ies
103
7/29/2016
131300 516
553 70 11 00 41
AOPSala
ies
106
7/29/2016
131300 516
553 70 11 00 41
AOPSala
ies
114
7/29/2016
131300 516
553 70 11 00 41
AOPSala
ies
117
7/29/2016
131300 516
553 70 11 00 41
AOPSala
ies
119
7/29/2016
131300 516
553 70 11 00 41
AOPSala
ies
120
7/29/2016
131300 516
553 70 11 00 41
AOPSala
ies
122
7/29/2016
1523
131300 516
553 70 11 00 41
AOPSala
ies
123
7/29/2016
1524
131300 516
553 70 11 00 41
AOPSala
ies
123
7/29/2016
1524
131300 516
553 70 11 00 41
AOPSala
ies
124
7/29/2016
1525
131300 516
553 70 11 00 41
AOPSala
ies
125
7/29/2016
1526
131300 516
553 70 11 00 41
AOPSala
ies
170
8/15/2016
131300 516
553 70 11 00 41
AOPSala
ies
171
8/15/2016
131300 516
553 70 11 00 41
AOPSala
ies
174
8/15/2016
131300 516
553 70 11 00 41
AOPSala
ies
178
8/15/2016
131300 516
553 70 11 00 41
AOPSala
ies
181
8/15/2016
131300 516
553 70 11 00 41
AOPSala
ies
183
8/15/2016
131300 516
553 70 11 00 41
AOPSala
ies
184
8/15/2016
131300 516
553 70 11 00 41
AOPSala
ies
186
8/15/2016
1542
131300 516
553 70 11 00 41
AOPSala
ies
187
8/15/2016
1543
131300 516
553 70 11 00 41
AOPSala
ies
187
8/15/2016
1543
131300 516
553 70 11 00 41
AOPSala
ies
188
8/15/2016
1544
131300 516
553 70 11 00 41
AOPSala
ies
188
8/15/2016
1544
131300 516
553 70 11 00 41
AOPSala
ies
188
8/15/2016
1544
131300 516
553 70 11 00 41
AOPSala
ies
189
8/15/2016
1545
131300 516
553 70 11 00 41
AOPSala
ies
190
8/15/2016
1546
131300 516
553 70 11 00 41
AOPSala
ies
254
8/31/2016
-------
131300 516
553 70
11 00 41
AOPSa
a
ies
255
8/31/2016
1
131300 516
553 70
11 00 41
AOPSa
a
ies
258
8/31/2016
1
131300 516
553 70
11 00 41
AOPSa
a
ies
262
8/31/2016
1
131300 516
553 70
11 00 41
AOPSa
a
ies
265
8/31/2016
1
131300 516
553 70
11 00 41
AOPSa
a
ies
267
8/31/2016
1
131300 516
553 70
11 00 41
AOPSa
a
ies
268
8/31/2016
1
131300 516
553 70
11 00 41
AOPSa
a
ies
270
8/31/2016
1 1570
131300 516
553 70
11 00 41
AOPSa
a
ies
271
8/31/2016
1 1571
131300 516
553 70
11 00 41
AOPSa
a
ies
271
8/31/2016
1 1571
131300 516
553 70
11 00 41
AOPSa
a
ies
272
8/31/2016
1 1572
131300 516
553 70
11 00 41
AOPSa
a
ies
273
8/31/2016
1 1573
131300 516
553 70
11 00 41
AOPSa
a
ies
332
9/15/2016
1
131300 516
553 70
11 00 41
AOPSa
a
ies
333
9/15/2016
1
131300 516
553 70
11 00 41
AOPSa
a
ies
338
9/15/2016
1
131300 516
553 70
11 00 41
AOPSa
a
ies
343
9/15/2016
1
131300 516
553 70
11 00 41
AOPSa
a
ies
346
9/15/2016
1
131300 516
553 70
11 00 41
AOPSa
a
ies
348
9/15/2016
1
131300 516
553 70
11 00 41
AOPSa
a
ies
349
9/15/2016
1
131300 516
553 70
11 00 41
AOPSa
a
ies
353
9/15/2016
1 1596
131300 516
553 70
11 00 41
AOPSa
a
ies
354
9/15/2016
1 1597
131300 516
553 70
11 00 41
AOPSa
a
ies
354
9/15/2016
1 1597
131300 516
553 70
11 00 41
AOPSa
a
ies
355
9/15/2016
1 1598
131300 516
553 70
11 00 41
AOPSa
a
ies
355
9/15/2016
1 1598
131300 516
553 70
11 00 41
AOPSa
a
ies
355
9/15/2016
1 1598
131300 516
553 70
11 00 41
AOPSa
a
ies
356
9/15/2016
1 1599
131300 516
553 70
11 00 41
AOPSa
a
ies
357
9/15/2016
1 1600
131300 516
553 70
11 00 41
AOPSa
a
ies
431
9/30/2016
1
131300 516
553 70
11 00 41
AOPSa
a
ies
432
9/30/2016
1
131300 516
553 70
11 00 41
AOPSa
a
ies
435
9/30/2016
1
131300 516
553 70
11 00 41
AOPSa
a
ies
439
9/30/2016
1
131300 516
553 70
11 00 41
AOPSa
a
ies
442
9/30/2016
1
131300 516
553 70
11 00 41
AOPSa
a
ies
444
9/30/2016
1
131300 516
553 70
11 00 41
AOPSa
a
ies
445
9/30/2016
1
131300 516
553 70
11 00 41
AOPSa
a
ies
447
9/30/2016
1 1621
131300 516
553 70
11 00 41
AOPSa
a
ies
448
9/30/2016
1 1622
131300 516
553 70
11 00 41
AOPSa
a
ies
448
9/30/2016
1 1622
131300 516
553 70
11 00 41
AOPSa
a
ies
449
9/30/2016
1 1623
131300 516
553 70
11 00 41
AOPSa
a
ies
450
9/30/2016
1 1624
131300 516
553 70
11 00 41
AOPSa
a
ies
491
10/4/2016
1 1642
131300 516
553 70
11 00 41
AOPSa
a
ies
510
10/14/2016
1
131300 516
553 70
11 00 41
AOPSa
a
ies
511
10/14/2016
1
131300 516
553 70
11 00 41
AOPSa
a
ies
514
10/14/2016
1
131300 516
553 70
11 00 41
AOPSa
a
ies
518
10/14/2016
1
131300 516
553 70
11 00 41
AOPSa
a
ies
521
10/14/2016
1
131300 516
553 70
11 00 41
AOPSa
a
ies
523
10/14/2016
1
131300 516
553 70
11 00 41
AOPSa
a
ies
524
10/14/2016
1
131300 516
553 70
11 00 41
AOPSa
a
ies
526
10/14/2016
1 1651
-------
131300 516
553 70
11 00 41
AOPSa
a
ies
527
10/14/2016
1 1652
131300 516
553 70
11 00 41
AOPSa
a
ies
527
10/14/2016
1 1652
131300 516
553 70
11 00 41
AOPSa
a
ies
528
10/14/2016
1 1653
131300 516
553 70
11 00 41
AOPSa
a
ies
528
10/14/2016
1 1653
131300 516
553 70
11 00 41
AOPSa
a
ies
528
10/14/2016
1 1653
131300 516
553 70
11 00 41
AOPSa
a
ies
529
10/14/2016
1 1654
131300 516
553 70
11 00 41
AOPSa
a
ies
530
10/14/2016
1 1655
131300 516
553 70
11 00 41
AOPSa
a
ies
595
10/31/2016
1
131300 516
553 70
11 00 41
AOPSa
a
ies
596
10/31/2016
1
131300 516
553 70
11 00 41
AOPSa
a
ies
599
10/31/2016
1
131300 516
553 70
11 00 41
AOPSa
a
ies
603
10/31/2016
1
131300 516
553 70
11 00 41
AOPSa
a
ies
606
10/31/2016
1
131300 516
553 70
11 00 41
AOPSa
a
ies
608
10/31/2016
1
131300 516
553 70
11 00 41
AOPSa
a
ies
609
10/31/2016
1
131300 516
553 70
11 00 41
AOPSa
a
ies
614
10/31/2016
1 1685
131300 516
553 70
11 00 41
AOPSa
a
ies
615
10/31/2016
1 1686
131300 516
553 70
11 00 41
AOPSa
a
ies
615
10/31/2016
1 1686
131300 516
553 70
11 00 41
AOPSa
a
ies
616
10/31/2016
1 1687
131300 516
553 70
11 00 41
AOPSa
a
ies
617
10/31/2016
1 1688
131300 516
553 70
11 00 41
AOPSa
a
ies
681
11/15/2016
1
131300 516
553 70
11 00 41
AOPSa
a
ies
682
11/15/2016
1
131300 516
553 70
11 00 41
AOPSa
a
ies
685
11/15/2016
1
131300 516
553 70
11 00 41
AOPSa
a
ies
689
11/15/2016
1
131300 516
553 70
11 00 41
AOPSa
a
ies
693
11/15/2016
1
131300 516
553 70
11 00 41
AOPSa
a
ies
695
11/15/2016
1
131300 516
553 70
11 00 41
AOPSa
a
ies
696
11/15/2016
1
131300 516
553 70
11 00 41
AOPSa
a
ies
698
11/15/2016
1 1716
131300 516
553 70
11 00 41
AOPSa
a
ies
699
11/15/2016
1 1717
131300 516
553 70
11 00 41
AOPSa
a
ies
699
11/15/2016
1 1717
131300 516
553 70
11 00 41
AOPSa
a
ies
700
11/15/2016
1 1718
131300 516
553 70
11 00 41
AOPSa
a
ies
700
11/15/2016
1 1718
131300 516
553 70
11 00 41
AOPSa
a
ies
700
11/15/2016
1 1718
131300 516
553 70
11 00 41
AOPSa
a
ies
701
11/15/2016
1 1719
131300 516
553 70
11 00 41
AOPSa
a
ies
702
11/15/2016
1 1720
131300 516
553 70
11 00 41
AOPSa
a
ies
744
11/30/2016
1
131300 516
553 70
11 00 41
AOPSa
a
ies
745
11/30/2016
1
131300 516
553 70
11 00 41
AOPSa
a
ies
748
11/30/2016
1
131300 516
553 70
11 00 41
AOPSa
a
ies
752
11/30/2016
1
131300 516
553 70
11 00 41
AOPSa
a
ies
756
11/30/2016
1
131300 516
553 70
11 00 41
AOPSa
a
ies
758
11/30/2016
1
131300 516
553 70
11 00 41
AOPSa
a
ies
759
11/30/2016
1
131300 516
553 70
11 00 41
AOPSa
a
ies
762
11/30/2016
1 1735
131300 516
553 70
11 00 41
AOPSa
a
ies
763
11/30/2016
1 1736
131300 516
553 70
11 00 41
AOPSa
a
ies
763
11/30/2016
1 1736
131300 516
553 70
11 00 41
AOPSa
a
ies
764
11/30/2016
1 1737
131300 516
553 70
11 00 41
AOPSa
a
ies
765
11/30/2016
1 1738
131300 516
553 70
11 00 41
AOPSa
a
ies
830
12/15/2016
1
-------
131300 516
553 70
11 00 41
AOPSa
a
ies
831
12/15/2016
1
131300 516
553 70
11 00 41
AOPSa
a
ies
834
12/15/2016
1
131300 516
553 70
11 00 41
AOPSa
a
ies
838
12/15/2016
1
131300 516
553 70
11 00 41
AOPSa
a
ies
839
12/15/2016
1
131300 516
553 70
11 00 41
AOPSa
a
ies
842
12/15/2016
1
131300 516
553 70
11 00 41
AOPSa
a
ies
844
12/15/2016
1
131300 516
553 70
11 00 41
AOPSa
a
ies
845
12/15/2016
1
131300 516
553 70
11 00 41
AOPSa
a
ies
847
12/15/2016
1 1770
131300 516
553 70
11 00 41
AOPSa
a
ies
848
12/15/2016
1 1771
131300 516
553 70
11 00 41
AOPSa
a
ies
848
12/15/2016
1 1771
131300 516
553 70
11 00 41
AOPSa
a
ies
849
12/15/2016
1 1772
131300 516
553 70
11 00 41
AOPSa
a
ies
849
12/15/2016
1 1772
131300 516
553 70
11 00 41
AOPSa
a
ies
849
12/15/2016
1 1772
131300 516
553 70
11 00 41
AOPSa
a
ies
850
12/15/2016
1 1773
131300 516
553 70
11 00 41
AOPSa
a
ies
851
12/15/2016
1 1774
131300 516
553 70
11 00 41
AOPSa
a
ies
875
12/30/2016
1
131300 516
553 70
11 00 41
AOPSa
a
ies
876
12/30/2016
1
131300 516
553 70
11 00 41
AOPSa
a
ies
879
12/30/2016
1
131300 516
553 70
11 00 41
AOPSa
a
ies
883
12/30/2016
1
131300 516
553 70
11 00 41
AOPSa
a
ies
887
12/30/2016
1
131300 516
553 70
11 00 41
AOPSa
a
ies
889
12/30/2016
1
131300 516
553 70
11 00 41
AOPSa
a
ies
890
12/30/2016
1
131300 516
553 70
11 00 41
AOPSa
a
ies
892
12/30/2016
1 1778
131300 516
553 70
11 00 41
AOPSa
a
ies
893
12/30/2016
1 1779
131300 516
553 70
11 00 41
AOPSa
a
ies
893
12/30/2016
1 1779
131300 516
553 70
11 00 41
AOPSa
a
ies
894
12/30/2016
1 1780
131300 516
553 70
11 00 41
AOPSa
a
ies
895
12/30/2016
1 1781
131300 516
553 70
11 00 41
AOPSa
a
ies
1997
12/31/2016
131300 516
553 70
11 00 41
AOPSa
a
ies
963
1/5/2017
1 1814
131300 516
553 70
11 00 41
AOPSa
a
ies
989
1/13/2017
1
131300 516
553 70
11 00 41
AOPSa
a
ies
990
1/13/2017
1
131300 516
553 70
11 00 41
AOPSa
a
ies
993
1/13/2017
1
131300 516
553 70
11 00 41
AOPSa
a
ies
997
1/13/2017
1
131300 516
553 70
11 00 41
AOPSa
a
ies
1001
1/13/2017
1
131300 516
553 70
11 00 41
AOPSa
a
ies
1003
1/13/2017
1
131300 516
553 70
11 00 41
AOPSa
a
ies
1004
1/13/2017
1
131300 516
553 70
11 00 41
AOPSa
a
ies
1006
1/13/2017
1 1832
131300 516
553 70
11 00 41
AOPSa
a
ies
1007
1/13/2017
1 1833
131300 516
553 70
11 00 41
AOPSa
a
ies
1007
1/13/2017
1 1833
131300 516
553 70
11 00 41
AOPSa
a
ies
1008
1/13/2017
1 1834
131300 516
553 70
11 00 41
AOPSa
a
ies
1008
1/13/2017
1 1834
131300 516
553 70
11 00 41
AOPSa
a
ies
1009
1/13/2017
1 1835
131300 516
553 70
11 00 41
AOPSa
a
ies
1010
1/13/2017
1 1836
131300 516
553 70
11 00 41
AOPSa
a
ies
1187
1/30/2017
1
131300 516
553 70
11 00 41
AOPSa
a
ies
1188
1/30/2017
1
131300 516
553 70
11 00 41
AOPSa
a
ies
1191
1/30/2017
1
131300 516
553 70
11 00 41
AOPSa
a
ies
1194
1/30/2017
1
-------
131300 516
553 70
11 00 41
AOPSa
a
ies
1198
1/30/2017
1
131300 516
553 70
11 00 41
AOPSa
a
ies
1200
1/30/2017
1
131300 516
553 70
11 00 41
AOPSa
a
ies
1201
1/30/2017
1
131300 516
553 70
11 00 41
AOPSa
a
ies
1229
1/30/2017
1 1876
131300 516
553 70
11 00 41
AOPSa
a
ies
1231
1/30/2017
1 1870
131300 516
553 70
11 00 41
AOPSa
a
ies
1233
1/30/2017
1 1872
131300 516
553 70
11 00 41
AOPSa
a
ies
1433
1/30/2017
1
131300 516
553 70
11 00 41
AOPSa
a
ies
1433
1/30/2017
1
131300 516
553 70
11 00 41
AOPSa
a
ies
1399
2/15/2017
1
131300 516
553 70
11 00 41
AOPSa
a
ies
1402
2/15/2017
1
131300 516
553 70
11 00 41
AOPSa
a
ies
1414
2/15/2017
1
131300 516
553 70
11 00 41
AOPSa
a
ies
1418
2/15/2017
1
131300 516
553 70
11 00 41
AOPSa
a
ies
1422
2/15/2017
1
131300 516
553 70
11 00 41
AOPSa
a
ies
1424
2/15/2017
1
131300 516
553 70
11 00 41
AOPSa
a
ies
1425
2/15/2017
1
131300 516
553 70
11 00 41
AOPSa
a
ies
1437
2/15/2017
1
131300 516
553 70
11 00 41
AOPSa
a
ies
1437
2/15/2017
1
131300 516
553 70
11 00 41
AOPSa
a
ies
1438
2/15/2017
1
131300 516
553 70
11 00 41
AOPSa
a
ies
1439
2/15/2017
1
131300 516
553 70
11 00 41
AOPSa
a
ies
1441
2/15/2017
1 1879
131300 516
553 70
11 00 41
AOPSa
a
ies
1442
2/15/2017
1 1880
131300 516
553 70
11 00 41
AOPSa
a
ies
1442
2/15/2017
1 1880
131300 516
553 70
11 00 41
AOPSa
a
ies
1563
2/28/2017
1
131300 516
553 70
11 00 41
AOPSa
a
ies
1564
2/28/2017
1
131300 516
553 70
11 00 41
AOPSa
a
ies
1567
2/28/2017
1
131300 516
553 70
11 00 41
AOPSa
a
ies
1570
2/28/2017
1
131300 516
553 70
11 00 41
AOPSa
a
ies
1576
2/28/2017
1
131300 516
553 70
11 00 41
AOPSa
a
ies
1578
2/28/2017
1
131300 516
553 70
11 00 41
AOPSa
a
ies
1579
2/28/2017
1
131300 516
553 70
11 00 41
AOPSa
a
ies
1624
2/28/2017
1 1923
131300 516
553 70
11 00 41
AOPSa
a
ies
1626
2/28/2017
1
131300 516
553 70
11 00 41
AOPSa
a
ies
1626
2/28/2017
1
131300 516
553 70
11 00 41
AOPSa
a
ies
1627
2/28/2017
1
131300 516
553 70
11 00 41
AOPSa
a
ies
1628
2/28/2017
1
131300 516
553 70
11 00 41
AOPSa
a
ies
1840
3/15/2017
1
131300 516
553 70
11 00 41
AOPSa
a
ies
1841
3/15/2017
1
131300 516
553 70
11 00 41
AOPSa
a
ies
1846
3/15/2017
1
131300 516
553 70
11 00 41
AOPSa
a
ies
1850
3/15/2017
1
131300 516
553 70
11 00 41
AOPSa
a
ies
1854
3/15/2017
1
131300 516
553 70
11 00 41
AOPSa
a
ies
1856
3/15/2017
1
131300 516
553 70
11 00 41
AOPSa
a
ies
1857
3/15/2017
1
131300 516
553 70
11 00 41
AOPSa
a
ies
1868
3/15/2017
1 10034
131300 516
553 70
11 00 41
AOPSa
a
ies
1869
3/15/2017
1 10035
131300 516
553 70
11 00 41
AOPSa
a
ies
1869
3/15/2017
1 10035
131300 516
553 70
11 00 41
AOPSa
a
ies
1874
3/15/2017
1
131300 516
553 70
11 00 41
AOPSa
a
ies
1875
3/15/2017
1
131300 516
553 70
11 00 41
AOPSa
a
ies
1875
3/15/2017
1
-------
131
300 516
553
70
11
00 41
AOPSa
a
ies
1876
3/15/2017
131
300 516
553
70
11
00 41
AOPSa
a
ies
1922
3/31/2017
131
300 516
553
70
11
00 41
AOPSa
a
ies
1923
3/31/2017
131
300 516
553
70
11
00 41
AOPSa
a
ies
1926
3/31/2017
131
300 516
553
70
11
00 41
AOPSa
a
ies
1929
3/31/2017
131
300 516
553
70
11
00 41
AOPSa
a
ies
1933
3/31/2017
131
300 516
553
70
11
00 41
AOPSa
a
ies
1935
3/31/2017
131
300 516
553
70
11
00 41
AOPSa
a
ies
1936
3/31/2017
131
300 516
553
70
11
00 41
AOPSa
a
ies
1956
3/31/2017
131
300 516
553
70
11
00 41
AOPSa
a
ies
2000
3/31/2017
131
300 516
553
70
11
00 41
AOPSa
a
ies
2000
3/31/2017
131
300 516
553
70
11
00 41
AOPSa
a
ies
2001
3/31/2017
131
300 516
553
70
11
00 41
AOPSa
a
ies
2003
3/31/2017
131
300 516
553
70
11
00 41
AOPSa
a
ies
2115
4/12/2017
131
300 516
553
70
11
00 41
AOPSa
a
ies
2061
4/14/2017
131
300 516
553
70
11
00 41
AOPSa
a
ies
2062
4/14/2017
131
300 516
553
70
11
00 41
AOPSa
a
ies
2065
4/14/2017
131
300 516
553
70
11
00 41
AOPSa
a
ies
2069
4/14/2017
131
300 516
553
70
11
00 41
AOPSa
a
ies
2071
4/14/2017
131
300 516
553
70
11
00 41
AOPSa
a
ies
2072
4/14/2017
131
300 516
553
70
11
00 41
AOPSa
a
ies
2075
4/14/2017
131
300 516
553
70
11
00 41
AOPSa
a
ies
2103
4/14/2017
131
300 516
553
70
11
00 41
AOPSa
a
ies
2105
4/14/2017
131
300 516
553
70
11
00 41
AOPSa
a
ies
2106
4/14/2017
131
300 516
553
70
11
00 41
AOPSa
a
ies
2106
4/14/2017
131
300 516
553
70
11
00 41
AOPSa
a
ies
2114
4/14/2017
131
300 516
553
70
11
00 41
AOPSa
a
ies
2168
4/28/2017
131
300 516
553
70
11
00 41
AOPSa
a
ies
2169
4/28/2017
131
300 516
553
70
11
00 41
AOPSa
a
ies
2172
4/28/2017
131
300 516
553
70
11
00 41
AOPSa
a
ies
2175
4/28/2017
131
300 516
553
70
11
00 41
AOPSa
a
ies
2179
4/28/2017
131
300 516
553
70
11
00 41
AOPSa
a
ies
2181
4/28/2017
131
300 516
553
70
11
00 41
AOPSa
a
ies
2182
4/28/2017
131
300 516
553
70
11
00 41
AOPSa
a
ies
2190
4/28/2017
131
300 516
553
70
11
00 41
AOPSa
a
ies
2191
4/28/2017
131
300 516
553
70
11
00 41
AOPSa
a
ies
2193
4/28/2017
131
300 516
553
70
11
00 41
AOPSa
a
ies
2195
4/28/2017
131
300 516
553
70
11
00 41
AOPSa
a
ies
2195
4/28/2017
131
300 516
553
70
11
00 41
AOPSa
a
ies
2246
5/15/2017
131
300 516
553
70
11
00 41
AOPSa
a
ies
2247
5/15/2017
131
300 516
553
70
11
00 41
AOPSa
a
ies
2249
5/15/2017
131
300 516
553
70
11
00 41
AOPSa
a
ies
2251
5/15/2017
131
300 516
553
70
11
00 41
AOPSa
a
ies
2253
5/15/2017
131
300 516
553
70
11
00 41
AOPSa
a
ies
2254
5/15/2017
131
300 516
553
70
11
00 41
AOPSa
a
ies
2259
5/15/2017
131
300 516
553
70
11
00 41
AOPSa
a
ies
2265
5/15/2017
131
300 516
553
70
11
00 41
AOPSa
a
ies
2265
5/15/2017
-------
131300 516
553 70 11 00 41
AOP Salaries
2267
5/15/2017
1
131300 516
553 70 11 00 41
AOP Salaries
2269
5/15/2017
1 10141
131300 516
553 70 11 00 41
AOP Salaries
2269
5/15/2017
1 10141
131300 516
553 70 11 00 41
AOP Salaries
2270
5/15/2017
1
131300 516
553 70 11 00 41
AOP Salaries
2327
5/31/2017
1
131300 516
553 70 11 00 41
AOP Salaries
2328
5/31/2017
1
131300 516
553 70 11 00 41
AOP Salaries
2331
5/31/2017
1
131300 516
553 70 11 00 41
AOP Salaries
2334
5/31/2017
1
131300 516
553 70 11 00 41
AOP Salaries
2338
5/31/2017
1
131300 516
553 70 11 00 41
AOP Salaries
2340
5/31/2017
1
131300 516
553 70 11 00 41
AOP Salaries
2341
5/31/2017
1
131300 516
553 70 11 00 41
AOP Salaries
2348
5/31/2017
1
131300 516
553 70 11 00 41
AOP Salaries
2348
5/31/2017
1
131300 516
553 70 11 00 41
AOP Salaries
2349
5/31/2017
1
131300 516
553 70 11 00 41
AOP Salaries
2350
5/31/2017
1
131300 516
553 70 11 00 41
AOP Salaries
2352
5/31/2017
1 10172
131300 516
553 70 11 00 41
AOP Salaries
2428
6/15/2017
1
131300 516
553 70 11 00 41
AOP Salaries
2429
6/15/2017
1
131300 516
553 70 11 00 41
AOP Salaries
2432
6/15/2017
1
131300 516
553 70 11 00 41
AOP Salaries
2435
6/15/2017
1
131300 516
553 70 11 00 41
AOP Salaries
2439
6/15/2017
1
131300 516
553 70 11 00 41
AOP Salaries
2441
6/15/2017
1
131300 516
553 70 11 00 41
AOP Salaries
2442
6/15/2017
1
131300 516
553 70 11 00 41
AOP Salaries
2444
6/15/2017
1
131300 516
553 70 11 00 41
AOP Salaries
2444
6/15/2017
1
131300 516
553 70 11 00 41
AOP Salaries
2445
6/15/2017
1
131300 516
553 70 11 00 41
AOP Salaries
2446
6/15/2017
1
131300 516
553 70 11 00 41
AOP Salaries
2448
6/15/2017
1 10194
131300 516
553 70 11 00 41
AOP Salaries
2448
6/15/2017
1 10194
131300 516
553 70 11 00 41
AOP Salaries
2515
6/30/2017
1
131300 516
553 70 11 00 41
AOP Salaries
2516
6/30/2017
1
131300 516
553 70 11 00 41
AOP Salaries
2519
6/30/2017
1
131300 516
553 70 11 00 41
AOP Salaries
2522
6/30/2017
1
131300 516
553 70 11 00 41
AOP Salaries
2526
6/30/2017
1
131300 516
553 70 11 00 41
AOP Salaries
2528
6/30/2017
1
131300 516
553 70 11 00 41
AOP Salaries
2529
6/30/2017
1
131300 516
553 70 11 00 41
AOP Salaries
2538
6/30/2017
1
131300 516
553 70 11 00 41
AOP Salaries
2538
6/30/2017
1
131300 516
553 70 11 00 41
AOP Salaries
2539
6/30/2017
1
131300 516
553 70 11 00 41
AOP Salaries
2540
6/30/2017
1
131300 516
553 70 11 00 41
AOP Salaries
2543
6/30/2017
1 10222
131300 516
553 70 21 00 41
AOP Benefits
38
7/15/2016
1 1481
131300 516
553 70 21 00 41
AOP Benefits
38
7/15/2016
1 1481
131300 516
553 70 21 00 41
AOP Benefits
39
7/15/2016
1 1482
131300 516
553 70 21 00 41
AOP Benefits
41
7/15/2016
1 1484
131300 516
553 70 21 00 41
AOP Benefits
42
7/15/2016
1 1485
131300 516
553 70 21 00 41
AOP Benefits
123
7/29/2016
1 1524
-------
131300 516
553 70 21 00 41
AOP
Benef
ts
123
7/29/2016
1 1524
131300 516
553 70 21 00 41
AOP
Benef
ts
125
7/29/2016
1 1526
131300 516
553 70 21 00 41
AOP
Benef
ts
127
7/29/2016
1 1528
131300 516
553 70 21 00 41
AOP
Benef
ts
187
8/15/2016
1 1543
131300 516
553 70 21 00 41
AOP
Benef
ts
187
8/15/2016
1 1543
131300 516
553 70 21 00 41
AOP
Benef
ts
188
8/15/2016
1 1544
131300 516
553 70 21 00 41
AOP
Benef
ts
190
8/15/2016
1 1546
131300 516
553 70 21 00 41
AOP
Benef
ts
191
8/15/2016
1 1547
131300 516
553 70 21 00 41
AOP
Benef
ts
271
8/31/2016
1 1571
131300 516
553 70 21 00 41
AOP
Benef
ts
271
8/31/2016
1 1571
131300 516
553 70 21 00 41
AOP
Benef
ts
273
8/31/2016
1 1573
131300 516
553 70 21 00 41
AOP
Benef
ts
275
8/31/2016
1 1575
131300 516
553 70 21 00 41
AOP
Benef
ts
354
9/15/2016
1 1597
131300 516
553 70 21 00 41
AOP
Benef
ts
354
9/15/2016
1 1597
131300 516
553 70 21 00 41
AOP
Benef
ts
355
9/15/2016
1 1598
131300 516
553 70 21 00 41
AOP
Benef
ts
357
9/15/2016
1 1600
131300 516
553 70 21 00 41
AOP
Benef
ts
358
9/15/2016
1 1601
131300 516
553 70 21 00 41
AOP
Benef
ts
448
9/30/2016
1 1622
131300 516
553 70 21 00 41
AOP
Benef
ts
448
9/30/2016
1 1622
131300 516
553 70 21 00 41
AOP
Benef
ts
450
9/30/2016
1 1624
131300 516
553 70 21 00 41
AOP
Benef
ts
452
9/30/2016
1 1626
131300 516
553 70 21 00 41
AOP
Benef
ts
491
10/4/2016
1 1642
131300 516
553 70 21 00 41
AOP
Benef
ts
492
10/4/2016
1 1643
131300 516
553 70 21 00 41
AOP
Benef
ts
527
10/14/2016
1 1652
131300 516
553 70 21 00 41
AOP
Benef
ts
527
10/14/2016
1 1652
131300 516
553 70 21 00 41
AOP
Benef
ts
528
10/14/2016
1 1653
131300 516
553 70 21 00 41
AOP
Benef
ts
530
10/14/2016
1 1655
131300 516
553 70 21 00 41
AOP
Benef
ts
531
10/14/2016
1 1656
131300 516
553 70 21 00 41
AOP
Benef
ts
615
10/31/2016
1 1686
131300 516
553 70 21 00 41
AOP
Benef
ts
615
10/31/2016
1 1686
131300 516
553 70 21 00 41
AOP
Benef
ts
617
10/31/2016
1 1688
131300 516
553 70 21 00 41
AOP
Benef
ts
619
10/31/2016
1 1690
131300 516
553 70 21 00 41
AOP
Benef
ts
699
11/15/2016
1 1717
131300 516
553 70 21 00 41
AOP
Benef
ts
699
11/15/2016
1 1717
131300 516
553 70 21 00 41
AOP
Benef
ts
700
11/15/2016
1 1718
131300 516
553 70 21 00 41
AOP
Benef
ts
702
11/15/2016
1 1720
131300 516
553 70 21 00 41
AOP
Benef
ts
703
11/15/2016
1 1721
131300 516
553 70 21 00 41
AOP
Benef
ts
763
11/30/2016
1 1736
131300 516
553 70 21 00 41
AOP
Benef
ts
763
11/30/2016
1 1736
131300 516
553 70 21 00 41
AOP
Benef
ts
765
11/30/2016
1 1738
131300 516
553 70 21 00 41
AOP
Benef
ts
767
11/30/2016
1 1740
131300 516
553 70 21 00 41
AOP
Benef
ts
848
12/15/2016
1 1771
131300 516
553 70 21 00 41
AOP
Benef
ts
848
12/15/2016
1 1771
131300 516
553 70 21 00 41
AOP
Benef
ts
849
12/15/2016
1 1772
131300 516
553 70 21 00 41
AOP
Benef
ts
851
12/15/2016
1 1774
131300 516
553 70 21 00 41
AOP
Benef
ts
852
12/15/2016
1 1775
131300 516
553 70 21 00 41
AOP
Benef
ts
893
12/30/2016
1 1779
-------
131300 516
553 70 21 00 41
AOP
Benef
ts
893
12/30/2016
1 1779
131300 516
553 70 21 00 41
AOP
Benef
ts
895
12/30/2016
1 1781
131300 516
553 70 21 00 41
AOP
Benef
ts
897
12/30/2016
1 1783
131300 516
553 70 21 00 41
AOP
Benef
ts
1997
12/31/2016
131300 516
553 70 21 00 41
AOP
Benef
ts
963
1/5/2017
1 1814
131300 516
553 70 21 00 41
AOP
Benef
ts
965
1/5/2017
1 1816
131300 516
553 70 21 00 41
AOP
Benef
ts
1007
1/13/2017
1 1833
131300 516
553 70 21 00 41
AOP
Benef
ts
1007
1/13/2017
1 1833
131300 516
553 70 21 00 41
AOP
Benef
ts
1008
1/13/2017
1 1834
131300 516
553 70 21 00 41
AOP
Benef
ts
1010
1/13/2017
1 1836
131300 516
553 70 21 00 41
AOP
Benef
ts
1011
1/13/2017
1 1837
131300 516
553 70 21 00 41
AOP
Benef
ts
1230
1/30/2017
1 1875
131300 516
553 70 21 00 41
AOP
Benef
ts
1233
1/30/2017
1 1872
131300 516
553 70 21 00 41
AOP
Benef
ts
1433
1/30/2017
1
131300 516
553 70 21 00 41
AOP
Benef
ts
1433
1/30/2017
1
131300 516
553 70 21 00 41
AOP
Benef
ts
1437
2/15/2017
1
131300 516
553 70 21 00 41
AOP
Benef
ts
1437
2/15/2017
1
131300 516
553 70 21 00 41
AOP
Benef
ts
1439
2/15/2017
1
131300 516
553 70 21 00 41
AOP
Benef
ts
1440
2/15/2017
1
131300 516
553 70 21 00 41
AOP
Benef
ts
1442
2/15/2017
1 1880
131300 516
553 70 21 00 41
AOP
Benef
ts
1626
2/28/2017
1
131300 516
553 70 21 00 41
AOP
Benef
ts
1626
2/28/2017
1
131300 516
553 70 21 00 41
AOP
Benef
ts
1628
2/28/2017
1
131300 516
553 70 21 00 41
AOP
Benef
ts
1629
2/28/2017
1
131300 516
553 70 21 00 41
AOP
Benef
ts
1869
3/15/2017
1 10035
131300 516
553 70 21 00 41
AOP
Benef
ts
1874
3/15/2017
1
131300 516
553 70 21 00 41
AOP
Benef
ts
1875
3/15/2017
1
131300 516
553 70 21 00 41
AOP
Benef
ts
1875
3/15/2017
1
131300 516
553 70 21 00 41
AOP
Benef
ts
1877
3/15/2017
1
131300 516
553 70 21 00 41
AOP
Benef
ts
1956
3/31/2017
1
131300 516
553 70 21 00 41
AOP
Benef
ts
2000
3/31/2017
1
131300 516
553 70 21 00 41
AOP
Benef
ts
2000
3/31/2017
1
131300 516
553 70 21 00 41
AOP
Benef
ts
2002
3/31/2017
1
131300 516
553 70 21 00 41
AOP
Benef
ts
2115
4/12/2017
1 10095
131300 516
553 70 21 00 41
AOP
Benef
ts
2118
4/12/2017
1 10096
131300 516
553 70 21 00 41
AOP
Benef
ts
2103
4/14/2017
1
131300 516
553 70 21 00 41
AOP
Benef
ts
2104
4/14/2017
1
131300 516
553 70 21 00 41
AOP
Benef
ts
2106
4/14/2017
1 10093
131300 516
553 70 21 00 41
AOP
Benef
ts
2191
4/28/2017
1
131300 516
553 70 21 00 41
AOP
Benef
ts
2192
4/28/2017
1
131300 516
553 70 21 00 41
AOP
Benef
ts
2195
4/28/2017
1
131300 516
553 70 21 00 41
AOP
Benef
ts
2195
4/28/2017
1
131300 516
553 70 21 00 41
AOP
Benef
ts
2265
5/15/2017
1
131300 516
553 70 21 00 41
AOP
Benef
ts
2265
5/15/2017
1
131300 516
553 70 21 00 41
AOP
Benef
ts
2267
5/15/2017
1
131300 516
553 70 21 00 41
AOP
Benef
ts
2268
5/15/2017
1
131300 516
553 70 21 00 41
AOP
Benef
ts
2269
5/15/2017
1 10141
-------
131
300
516
553
70
21
00 41
AOP
Benef
ts
2348
5/31/2017
131
300
516
553
70
21
00 41
AOP
Benef
ts
2348
5/31/2017
131
300
516
553
70
21
00 41
AOP
Benef
ts
2350
5/31/2017
131
300
516
553
70
21
00 41
AOP
Benef
ts
2351
5/31/2017
131
300
516
553
70
21
00 41
AOP
Benef
ts
2444
6/15/2017
131
300
516
553
70
21
00 41
AOP
Benef
ts
2444
6/15/2017
131
300
516
553
70
21
00 41
AOP
Benef
ts
2446
6/15/2017
131
300
516
553
70
21
00 41
AOP
Benef
ts
2447
6/15/2017
131
300
516
553
70
21
00 41
AOP
Benef
ts
2448
6/15/2017
131
300
516
553
70
21
00 41
AOP
Benef
ts
2538
6/30/2017
131
300
516
553
70
21
00 41
AOP
Benef
ts
2538
6/30/2017
131
300
516
553
70
21
00 41
AOP
Benef
ts
2540
6/30/2017
131
300
516
553
70
21
00 41
AOP
Benef
ts
2541
6/30/2017
131
300
586
553
70
51
00 41
Indirect Expense AOP
2629
6/30/2017
-------
Trans Type
Vendor
Amount
Claims
Smoke School Inc
190.00
Claims
Smoke School Inc
190.00
Claims
April Westby
301.80
Payroll
John M Conklin
526.13
Payroll
Brandy M Dickinson
257.09
Payroll
Deirdre M Fitzgerald
-
Payroll
Mary L Kataoka
52.70
Payroll
Russell D Neumiller
-
Payroll
Joe R Southwell
312.24
Payroll
April L Westby
896.99
Payroll
AFLAC
8.74
Payroll
Department Of Retirement Systems
130.79
Payroll
Department Of Retirement Systems
50.19
Payroll
Health Care Authority
103.89
Payroll
Health Care Authority
4.62
Payroll
Health Care Authority
9.69
Payroll
Nationwide Retirement Solutions
250.52
Payroll
US Bank Taxes
348.49
Payroll
John M Conklin
173.97
Payroll
Brandy M Dickinson
518.97
Payroll
Mary L Kataoka
49.57
Payroll
Russell D Neumiller
-
Payroll
Lori J Rodriguez
88.62
Payroll
Joe R Southwell
404.04
Payroll
April L Westby
1,025.83
Payroll
AFLAC
12.84
Payroll
Department Of Retirement Systems
111.70
Payroll
Department Of Retirement Systems
73.58
Payroll
Nationwide Retirement Solutions
260.10
Payroll
US Bank Taxes
352.42
Payroll
John M Conklin
173.97
Payroll
Brandy M Dickinson
188.32
Payroll
Mary L Kataoka
175.26
Payroll
Russell D Neumiller
-
Payroll
Lori J Rodriguez
66.46
Payroll
Joe R Southwell
243.67
Payroll
April L Westby
948.29
Payroll
AFLAC
16.98
Payroll
Department Of Retirement Systems
126.41
Payroll
Department Of Retirement Systems
39.26
Payroll
Health Care Authority
131.17
Payroll
Health Care Authority
3.69
Payroll
Health Care Authority
8.81
Payroll
Nationwide Retirement Solutions
278.81
Payroll
US Bank Taxes
301.56
Payroll
John M Conklin
173.97
-------
Payroll
Brandy M Dickinson
203.88
Payroll
Mary L Kataoka
49.57
Payroll
Russell D Neumiller
-
Payroll
Lori J Rodriguez
66.47
Payroll
Joe R Southwell
404.04
Payroll
April L Westby
1,025.83
Payroll
AFLAC
7.06
Payroll
Department Of Retirement Systems
109.90
Payroll
Department Of Retirement Systems
51.86
Payroll
Nationwide Retirement Solutions
231.35
Payroll
US Bank Taxes
287.26
Payroll
John M Conklin
174.04
Payroll
Brandy M Dickinson
188.48
Payroll
Mary L Kataoka
89.25
Payroll
Russell D Neumiller
-
Payroll
Lori J Rodriguez
-
Payroll
Joe R Southwell
365.95
Payroll
April L Westby
1,066.58
Payroll
AFLAC
10.46
Payroll
Department Of Retirement Systems
120.57
Payroll
Department Of Retirement Systems
51.86
Payroll
Health Care Authority
10.26
Payroll
Health Care Authority
138.51
Payroll
Health Care Authority
5.05
Payroll
Nationwide Retirement Solutions
261.00
Payroll
US Bank Taxes
305.41
Payroll
John M Conklin
173.97
Payroll
Brandy M Dickinson
74.14
Payroll
Mary L Kataoka
49.57
Payroll
Russell D Neumiller
-
Payroll
Lori J Rodriguez
22.16
Payroll
Joe R Southwell
404.04
Payroll
April L Westby
1,041.01
Payroll
AFLAC
4.68
Payroll
Department Of Retirement Systems
107.46
Payroll
Department Of Retirement Systems
42.92
Payroll
Nationwide Retirement Solutions
216.61
Payroll
US Bank Taxes
257.54
Payroll
Dept Of Labor And Industry
31.41
Payroll
John M Conklin
574.25
Payroll
Brandy M Dickinson
673.52
Payroll
Mary L Kataoka
43.89
Payroll
Russell D Neumiller
-
Payroll
Lori J Rodriguez
212.56
Payroll
Joe R Southwell
365.56
Payroll
April L Westby
1,240.50
Payroll
AFLAC
16.69
-------
Payroll
Department Of Retirement Systems
181.54
Payroll
Department Of Retirement Systems
88.05
Payroll
Health Care Authority
180.29
Payroll
Health Care Authority
7.06
Payroll
Health Care Authority
16.81
Payroll
Nationwide Retirement Solutions
354.67
Payroll
US Bank Taxes
546.41
Payroll
John M Conklin
173.97
Payroll
Brandy M Dickinson
74.14
Payroll
Mary L Kataoka
49.57
Payroll
Russell D Neumiller
-
Payroll
Lori J Rodriguez
22.91
Payroll
Joe R Southwell
404.04
Payroll
April L Westby
1,041.01
Payroll
AFLAC
4.68
Payroll
Department Of Retirement Systems
107.53
Payroll
Department Of Retirement Systems
42.92
Payroll
Nationwide Retirement Solutions
216.68
Payroll
US Bank Taxes
257.81
Payroll
John M Conklin
210.45
Payroll
Brandy M Dickinson
451.23
Payroll
Mary L Kataoka
43.90
Payroll
Russell D Neumiller
-
Payroll
Lori J Rodriguez
22.91
Payroll
Joe R Southwell
290.12
Payroll
April L Westby
962.48
Payroll
AFLAC
12.28
Payroll
Department Of Retirement Systems
110.61
Payroll
Department Of Retirement Systems
63.68
Payroll
Health Care Authority
136.69
Payroll
Health Care Authority
5.23
Payroll
Health Care Authority
12.26
Payroll
Nationwide Retirement Solutions
242.81
Payroll
US Bank Taxes
338.58
Payroll
John M Conklin
173.97
Payroll
Brandy M Dickinson
74.14
Payroll
Mary L Kataoka
49.57
Payroll
Russell D Neumiller
-
Payroll
Lori J Rodriguez
22.91
Payroll
Joe R Southwell
404.04
Payroll
April L Westby
1,041.01
Payroll
AFLAC
4.68
Payroll
Department Of Retirement Systems
107.53
Payroll
Department Of Retirement Systems
42.92
Payroll
Nationwide Retirement Solutions
216.68
Payroll
US Bank Taxes
257.81
Payroll
John M Conklin
173.97
-------
Payroll
Brandy M Dickinson
772.53
Payroll
Mary L Kataoka
43.91
Payroll
Barbara Nelson
87.23
Payroll
Russell D Neumiller
-
Payroll
Lori J Rodriguez
22.91
Payroll
Joe R Southwell
365.70
Payroll
April L Westby
962.46
Payroll
AFLAC
20.63
Payroll
Department Of Retirement Systems
115.51
Payroll
Department Of Retirement Systems
95.48
Payroll
Health Care Authority
170.93
Payroll
Health Care Authority
7.37
Payroll
Health Care Authority
16.61
Payroll
Nationwide Retirement Solutions
289.94
Payroll
US Bank Taxes
426.74
Payroll
John M Conklin
174.02
Payroll
Brandy M Dickinson
74.21
Payroll
Mary L Kataoka
49.59
Payroll
Russell D Neumiller
-
Payroll
Lori J Rodriguez
22.92
Payroll
Joe R Southwell
404.12
Payroll
April L Westby
1,041.19
Payroll
AFLAC
4.68
Payroll
Department Of Retirement Systems
107.54
Payroll
Department Of Retirement Systems
42.92
Payroll
Nationwide Retirement Solutions
216.68
Payroll
US Bank Taxes
257.81
Adjustmt
Ncm Contracting Group LP
(1,845.33)
Payroll
Dept Of Labor And Industry
37.84
Payroll
John M Conklin
174.22
Payroll
Brandy M Dickinson
479.43
Payroll
Mary L Kataoka
149.56
Payroll
Russell D Neumiller
-
Payroll
Lori J Rodriguez
42.94
Payroll
Joe R Southwell
364.60
Payroll
April L Westby
853.28
Payroll
AFLAC
19.58
Payroll
Department Of Retirement Systems
111.28
Payroll
Department Of Retirement Systems
73.90
Payroll
Health Care Authority
149.92
Payroll
Health Care Authority
14.88
Payroll
Nationwide Retirement Solutions
290.34
Payroll
US Bank Taxes
349.69
Payroll
John M Conklin
174.17
Payroll
Brandy M Dickinson
74.19
Payroll
Mary L Kataoka
49.57
Payroll
Russell D Neumiller
-
-------
Payroll
Lori J Rodriguez
22.93
Payroll
Joe R Southwell
404.04
Payroll
April L Westby
1,041.38
Payroll
Nationwide Retirement Solutions
216.68
Payroll
AFLAC
4.68
Payroll
US Bank Taxes
257.18
Payroll
Department Of Retirement Systems
42.92
Payroll
Department Of Retirement Systems
107.53
Payroll
John M Conklin
174.28
Payroll
Brandy M Dickinson
67.92
Payroll
Mary L Kataoka
59.93
Payroll
Russell D Neumiller
-
Payroll
Lori J Rodriguez
22.94
Payroll
Joe R Southwell
364.65
Payroll
April L Westby
953.63
Payroll
Department Of Retirement Systems
42.92
Payroll
Department Of Retirement Systems
108.64
Payroll
Nationwide Retirement Solutions
221.19
Payroll
US Bank Taxes
259.29
Payroll
AFLAC
4.68
Payroll
Health Care Authority
124.97
Payroll
Health Care Authority
9.73
Payroll
John M Conklin
174.17
Payroll
Brandy M Dickinson
74.19
Payroll
Mary L Kataoka
59.87
Payroll
Russell D Neumiller
-
Payroll
Lori J Rodriguez
22.93
Payroll
Joe R Southwell
404.04
Payroll
April L Westby
1,041.38
Payroll
AFLAC
4.68
Payroll
Department Of Retirement Systems
108.63
Payroll
Department Of Retirement Systems
42.92
Payroll
Nationwide Retirement Solutions
221.19
Payroll
US Bank Taxes
259.29
Payroll
John M Conklin
182.56
Payroll
Brandy M Dickinson
67.94
Payroll
Mary L Kataoka
59.90
Payroll
Russell D Neumiller
-
Payroll
Lori J Rodriguez
22.96
Payroll
Joe R Southwell
364.60
Payroll
April L Westby
953.17
Payroll
AFLAC
4.68
Payroll
Health Care Authority
124.97
Payroll
Health Care Authority
9.73
Payroll
US Bank Taxes
259.43
Payroll
Department Of Retirement Systems
42.92
Payroll
Department Of Retirement Systems
109.22
-------
Payroll
Nationwide Retirement Solutions
221.78
Payroll
John M Conklin
180.32
Payroll
Brandy M Dickinson
74.19
Payroll
Mary L Kataoka
59.87
Payroll
Russell D Neumiller
-
Payroll
Lori J Rodriguez
22.93
Payroll
Joe R Southwell
397.74
Payroll
April L Westby
1,041.38
Payroll
US Bank Taxes
260.33
Payroll
Department Of Retirement Systems
109.22
Payroll
Department Of Retirement Systems
42.92
Payroll
Nationwide Retirement Solutions
229.28
Payroll
AFLAC
4.68
Payroll
Dept Of Labor And Industry
25.95
Payroll
John M Conklin
180.32
Payroll
Brandy M Dickinson
66.68
Payroll
Mary L Kataoka
59.94
Payroll
Lori J Rodriguez
22.93
Payroll
Joe R Southwell
358.18
Payroll
April L Westby
953.02
Payroll
Russell D Neumiller
-
Payroll
US Bank Taxes
260.33
Payroll
Nationwide Retirement Solutions
229.27
Payroll
Health Care Authority
124.97
Payroll
Health Care Authority
9.73
Payroll
AFLAC
5.84
Payroll
John M Conklin
180.32
Payroll
Brandy M Dickinson
73.03
Payroll
Mary L Kataoka
59.87
Payroll
Russell D Neumiller
-
Payroll
Lori J Rodriguez
22.93
Payroll
Joe R Southwell
397.74
Payroll
April L Westby
1,041.38
Payroll
Nationwide Retirement Solutions
229.28
Payroll
US Bank Taxes
260.33
Payroll
AFLAC
5.84
Payroll
Department Of Retirement Systems
109.22
Payroll
Department Of Retirement Systems
42.92
Payroll
John M Conklin
180.32
Payroll
Brandy M Dickinson
66.60
Payroll
Mary L Kataoka
59.93
Payroll
Russell D Neumiller
-
Payroll
Joe R Southwell
358.28
Payroll
April L Westby
953.92
Payroll
Lori J Rodriguez
22.95
Payroll
Department Of Retirement Systems
109.23
Payroll
Department Of Retirement Systems
42.92
-------
Payroll
US Bank Taxes
260.33
Payroll
Health Care Authority
124.97
Payroll
Health Care Authority
9.73
Payroll
Nationwide Retirement Solutions
229.27
Payroll
John M Conklin
180.32
Payroll
Brandy M Dickinson
73.03
Payroll
Mary L Kataoka
59.87
Payroll
Russell D Neumiller
-
Payroll
Lori J Rodriguez
22.93
Payroll
Joe R Southwell
397.74
Payroll
April L Westby
1,041.38
Payroll
Department Of Retirement Systems
109.22
Payroll
Department Of Retirement Systems
42.92
Payroll
Nationwide Retirement Solutions
229.28
Payroll
US Bank Taxes
260.33
Payroll
AFLAC
11.68
Payroll
John M Conklin
180.41
Payroll
Brandy M Dickinson
66.70
Payroll
Mary L Kataoka
60.00
Payroll
Russell D Neumiller
-
Payroll
Lori J Rodriguez
22.94
Payroll
Joe R Southwell
358.18
Payroll
April L Westby
953.32
Payroll
Department Of Retirement Systems
109.22
Payroll
Department Of Retirement Systems
42.92
Payroll
Nationwide Retirement Solutions
229.27
Payroll
US Bank Taxes
260.33
Payroll
Health Care Authority
124.97
Payroll
Health Care Authority
9.73
Payroll
John M Conklin
180.32
Payroll
Brandy M Dickinson
73.03
Payroll
Mary L Kataoka
59.87
Payroll
Russell D Neumiller
-
Payroll
Lori J Rodriguez
22.93
Payroll
Joe R Southwell
397.74
Payroll
April L Westby
1,041.38
Payroll
Department Of Retirement Systems
109.22
Payroll
Department Of Retirement Systems
42.92
Payroll
Nationwide Retirement Solutions
229.28
Payroll
US Bank Taxes
260.33
Payroll
AFLAC
11.68
Payroll
Department Of Retirement Systems
238.94
Payroll
Department Of Retirement Systems
91.57
Payroll
Health Care Authority
1,135.63
Payroll
US Bank Taxes
42.87
Payroll
Vantagepoint Transfer Agents 401
183.29
Payroll
Department Of Retirement Systems
204.05
-------
Payroll
Department Of Retirement Systems
140.38
Payroll
US Bank Taxes
44.67
Payroll
Vantagepoint Transfer Agents 401
191.01
Payroll
Department Of Retirement Systems
230.93
Payroll
Department Of Retirement Systems
71.68
Payroll
Health Care Authority
1,185.34
Payroll
US Bank Taxes
39.25
Payroll
Vantagepoint Transfer Agents 401
167.83
Payroll
Department Of Retirement Systems
200.76
Payroll
Department Of Retirement Systems
91.81
Payroll
US Bank Taxes
37.95
Payroll
Vantagepoint Transfer Agents 401
162.26
Payroll
Department Of Retirement Systems
220.25
Payroll
Department Of Retirement Systems
91.81
Payroll
Health Care Authority
1,189.02
Payroll
US Bank Taxes
40.47
Payroll
Vantagepoint Transfer Agents 401
173.07
Payroll
Department Of Retirement Systems
196.32
Payroll
Department Of Retirement Systems
71.82
Payroll
US Bank Taxes
34.77
Payroll
Vantagepoint Transfer Agents 401
148.71
Payroll
Dept Of Labor And Industry
82.14
Payroll
Employment Security Department
31.43
Payroll
Department Of Retirement Systems
331.64
Payroll
Department Of Retirement Systems
172.74
Payroll
Health Care Authority
1,817.69
Payroll
US Bank Taxes
65.41
Payroll
Vantagepoint Transfer Agents 401
279.71
Payroll
Department Of Retirement Systems
196.45
Payroll
Department Of Retirement Systems
71.82
Payroll
US Bank Taxes
34.78
Payroll
Vantagepoint Transfer Agents 401
148.78
Payroll
Department Of Retirement Systems
202.07
Payroll
Department Of Retirement Systems
123.21
Payroll
Health Care Authority
1,231.01
Payroll
US Bank Taxes
42.18
Payroll
Vantagepoint Transfer Agents 401
180.39
Payroll
Department Of Retirement Systems
196.45
Payroll
Department Of Retirement Systems
71.82
Payroll
US Bank Taxes
34.78
Payroll
Vantagepoint Transfer Agents 401
148.78
Payroll
Department Of Retirement Systems
211.03
Payroll
Department Of Retirement Systems
189.34
Payroll
Health Care Authority
1,547.24
Payroll
US Bank Taxes
51.91
Payroll
Vantagepoint Transfer Agents 401
222.04
Payroll
Department Of Retirement Systems
196.46
-------
Payroll
Department Of Retirement Systems
71.82
Payroll
US Bank Taxes
34.78
Payroll
Vantagepoint Transfer Agents 401
148.78
Adjustmt
Ncm Contracting Group LP
308.86
Payroll
Dept Of Labor And Industry
103.35
Payroll
Employment Security Department
13.52
Payroll
Department Of Retirement Systems
203.30
Payroll
Department Of Retirement Systems
141.10
Payroll
Health Care Authority
1,439.59
Payroll
US Bank Taxes
44.66
Payroll
Vantagepoint Transfer Agents 401
190.99
Payroll
Vantagepoint Transfer Agents 401
148.78
Payroll
US Bank Taxes
34.78
Payroll
Department Of Retirement Systems
71.82
Payroll
Department Of Retirement Systems
196.45
Payroll
Department Of Retirement Systems
71.82
Payroll
Department Of Retirement Systems
198.46
Payroll
US Bank Taxes
35.04
Payroll
Vantagepoint Transfer Agents 401
149.90
Payroll
Health Care Authority
1,081.16
Payroll
Department Of Retirement Systems
198.46
Payroll
Department Of Retirement Systems
71.82
Payroll
US Bank Taxes
35.04
Payroll
Vantagepoint Transfer Agents 401
149.90
Payroll
Health Care Authority
1,081.17
Payroll
US Bank Taxes
35.18
Payroll
Department Of Retirement Systems
71.82
Payroll
Department Of Retirement Systems
199.54
Payroll
Vantagepoint Transfer Agents 401
150.49
Payroll
US Bank Taxes
35.18
Payroll
Department Of Retirement Systems
199.53
Payroll
Department Of Retirement Systems
71.82
Payroll
Vantagepoint Transfer Agents 401
150.49
Payroll
Dept Of Labor And Industry
62.54
Payroll
Employment Security Department
56.13
Payroll
US Bank Taxes
35.18
Payroll
Vantagepoint Transfer Agents 401
150.49
Payroll
Health Care Authority
1,081.16
Payroll
US Bank Taxes
35.18
Payroll
Vantagepoint Transfer Agents 401
150.49
Payroll
Department Of Retirement Systems
199.53
Payroll
Department Of Retirement Systems
71.82
Payroll
Department Of Retirement Systems
199.54
Payroll
Department Of Retirement Systems
71.82
Payroll
US Bank Taxes
35.18
Payroll
Vantagepoint Transfer Agents 401
150.49
Payroll
Health Care Authority
1,081.17
-------
Payroll
Department Of Retirement Systems
199.53
Payroll
Department Of Retirement Systems
71.82
Payroll
US Bank Taxes
35.18
Payroll
Vantagepoint Transfer Agents 401
150.49
Payroll
Department Of Retirement Systems
199.53
Payroll
Department Of Retirement Systems
71.82
Payroll
US Bank Taxes
35.18
Payroll
Vantagepoint Transfer Agents 401
150.49
Payroll
Health Care Authority
1,081.16
Payroll
Department Of Retirement Systems
199.53
Payroll
Department Of Retirement Systems
71.82
Payroll
US Bank Taxes
35.18
Payroll
Vantagepoint Transfer Agents 401
150.49
Adjustmt
Ncm Contracting Group LP
102,173.00
192,798.59
-------
Remark
Smoke School
AOP Travel/Training
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001 Indirect Recovery - AOP
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SPOKANE COUNTY AIR POLLUTION CONTROL AUTHORITY
EPA TITLE V PROGRAM REVIEW "ACTION PLAN"
As requested in the Introduction section of the report, SCAPCA is responding to the concerns identified in the report. SCAPCA's
responses are structured to match the formatting and numbering conventions used in EPA's report.
A. Title V Permit Preparation and Content
EPA Concern
Proposed SCAPCA Action to Address
Concern
Schedule for SCAPCA
Action to Address
Concern
2018 Status of EPA
Concern
1. Table format used
by SCAPCA in permits
SCAPCA would prefer to continue using the table
format in our Title V permits for several reasons.
First, our sources like the table format for ease of
reading and because it is what they are
accustomed to seeing. Second, as stated in the
report, other permitting authorities in Washington
use the table format, which leads to more state-
wide consistency and uniformity in permits written
by local authorities in Washington. Lastly,
SCAPCA's format includes all of the required
elements for a Title V permit.
N/A
SRCAA is still using
table format in permits
2. Statements of basis
should contain a
discussion of facility's
compliance history
In the future, SCAPCA will add a discussion of
the facility's compliance history to the statements
of basis.
SCAPCA will implement
action in all new and
renewal permits drafted
from this point forward
SRCAA includes a
section on facility's
compliance history in
statements of basis.
3. Statements of basis
should contain a
discussion of facility
permitting history
In the future, SCAPCA will add a discussion of
the facility permitting history to the statements of
basis
SCAPCA will implement
action in all new and
renewal permits drafted
from this point forward
SRCAA includes a
section on facility's
permitting history in
statements of basis.
4. Statements of basis
should indicate whether
a facility is a major
source of HAPs
In the future, SCAPCA will add a discussion of
whether the facility is a major source of HAPs to
the statements of basis
SCAPCA will implement
action in all new and
renewal permits drafted
from this point forward
SRCAA includes a
discussion of the
whether the facility is a
major source of HAPs in
the statements of basis.
SCAPCA
EPA TITLE V PROGRAM REVIEW ACTION PLAN
PAGE 1 OF 7
11/9/2018
-------
C. Monitoring
EPA Concern
Proposed SCAPCA Action to Address Concern
Schedule for SCAPCA
Action to Address
Concern
2018 Status of EPA
Concern
1. SCAPCA's permits
contain general
testing requriements
that allow alternative
test methods
approved by SCAPCA
In the future, for federal testing requirements,
SCAPCA will take "alternate test methods
approved by SCAPCA" out of the permits.
However, for non-federal testing requirements,
permits will continue to allow for "alternate test
methods approved by SCAPCA," especially if this
provision is contained in the underlying
requirement (e.g., NOC approval order).
SCAPCA will implement
action in all new and
renewal permits drafted
from this point forward
SRCAA does not
include any alternate
test methods for federal
testing requirements.
2. SCAPCA's permits
do not include all
compliance assurance
provisions (e.g.,
monitoring plans) in
permit.
In the future, SCAPCA will pull key provisions for
assuring compliance with the emission limits from
monitoring plans, such as the pressure drop range
for a scrubber, and include them in the permit.
SCAPCA already does this as a general practice.
However, when an operation and maintenance
plan includes best management practices and
other procedural requirements and does not
include measurable parameters or other key
provisions that assure compliance with an
emission limit, SCAPCA would prefer to keep the
plan "off-permit." SCAPCA would also prefer to
keep lengthy operation plans which are revised
regularly, such as the one developed for our
Waste-to-Energy facility, off-permit. Many of the
revisions made to these plans would not have a
direct correlation with any emission limit for the
facility. If SCAPCA were required to revise an air
operating permit for each change to an operation
plan, this would cause a significant workload
increase with little air quality benefit.
SCAPCA will implement
action in all new and
renewal permits drafted
from this point forward
SRCAA pulls out key
provisions, when
possible, and includes
them in the permit for
assuring compliance
with emission limits.
However, for facilities
with long and/or
complicated O&M plans
which are revised
routinely, SRCAA still
keeps the plan "off-
permt."
3. Some of
SCAPCA's permits
In the future, SCAPCA will strive to establish a
relationship between a particulate limit and opacity
SCAPCA will implement
action in all new and
SRCAA strives to
establish a relationship
SCAPCA
EPA TITLE V PROGRAM REVIEW ACTION PLAN
PAGE 2 OF 7
11/9/2018
-------
allow for visible
emission observations
with a particulate limit
other than opacity.
through emission testing or other reliable
information, when opacity is used to monitor
compliance with a particulate limit. However, this
approach will only be used when opacity levels
higher than 0% are used to demonstrate
compliance with a particulate limit. SCAPCA will
continue to use the "no visible emissions" (a.k.a.,
"smoke / no smoke") concept as monitoring for
particulate emission standards, without an
established relationship between a particulate limit
and opacity, because we concur that something
will be visible before a compliance problem exists.
renewal permits drafted
from this point forward
between particulate limit
and opacity, when data
is available. SRCAA still
uses the "no visible
emissions" concept as
monitoring for
particulate emission
standards without an
established relationship.
4. The frequency of
source testing should
be based on how
close actual emissions
are to the standard
SCAPCA does base the frequency of source
testing on how close actual emissions are to the
standard. However, SCAPCA also bases the
frequency of source testing on how often the
equipment operates. For the Avista peaking plant,
which was referenced in the draft report, this
equipment only runs every ~ 3 years, other than
for testing purposes. SCAPCA does not think it is
appropriate to require the equipment to operate
solely for the purpose of testing the emissions.
The peaking plant is required to be tested every
1,700 hours of operation (which would be
triggered every three months, if the equipment
was to run continuously) or every 5 years,
whichever occurs first. SCAPCA believes that this
approach is justifiable and adequately assures
compliance with the emission limits, especially
given in the frequency of operation for the
equipment. SCAPCA also does require
monitoring of the operational parameters that were
monitored during the source test to ensure that the
equipment is operating in the same manner as it
did during the test. In the case of the Avista
peaking plant, the only pertinent parameter to
SCAPCA will implement
action in all new and
renewal permits drafted
from this point forward
SRCAA bases the
frequency of source
testing on how close the
actual emissions are to
the standard and how
often the equipment
operates.
SCAPCA
EPA TITLE V PROGRAM REVIEW ACTION PLAN
PAGE 3 OF 7
11/9/2018
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monitor (since these are uncontrolled turbines,
except for the oxidation catalysts) is the oxidation
catalyst pressure drop. This parameter is required
to be kept within the acceptable range specified in
the O&M plan. SCAPCA did ensure that the
acceptable range in the O&M plan was in-line with
the pressure drop monitored during the source
test. However, this fact was not well documented
in the statement of basis. In the future, SCAPCA
will more clearly document the relationships
between required monitoring and operational
parameters that are monitored during source tests
in the statements of basis.
5. The MRRR in
permits are numbered
such that it difficult to
cite a particular
section of a
requirement
SCAPCA will attempt to separate out various
sections of monitoring, recordkeeping, and
reporting requirements, when appropriate and
useful.
SCAPCA will implement
action in all new and
renewal permits drafted
from this point forward
SRCAA attempts to
separate out various
sections of MRRR,
when it is appropriate
and/or possible.
D. Public Participation and Affected State Review
EPA Concern
Proposed SCAPCA Action to Address Concern
Schedule for SCAPCA
Action to Address
Concern
2018 Status of EPA
Concern
1. SCAPCA'spre-
draft permit work with
permittees can create
the impression that
the permit issuance
process is not an
open process
During the public comment period on the draft
permit, the public is welcome to look at SCAPCA's
Air Operating Permit review files, which contains
all "pre-draft" permit work and communications
between the permittee and SCAPCA. During the
public comment period, all comments received,
including any comments on "pre-draft" permit
work, is considered and addressed by SCAPCA.
N/A
SRCAA's practice
remains the same on
"pre-draft" work
SCAPCA
EPA TITLE V PROGRAM REVIEW ACTION PLAN
PAGE 4 OF 7
11/9/2018
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E. Permit / Issuance / Revision / Renewal
EPA Concern
Proposed SCAPCA Action to Address Concern
Schedule for SCAPCA
Action to Address
Concern
2018 Status of EPA
Concern
1. Three of the four
renewal applications
received by SCAPCA
were issued late.
SCAPCA attempts to issue all permits in a timely
fashion. However, there are occasions when
resource constraints and factors that are out of
SCAPCA's control may cause a renewal permit to
be issued after the initial permit expiration date.
However, the facility would not be without a
permit, since the initial permit remains in effect
after the initial permit expires, provided that the
applicant has submitted a timely renewal
application to SCAPCA.
N/A
SRCAA's practice
remains the same on
renewal applications.
Resource constraints
and other factors are still
present and create
backlogs for renewal
permits.
F. Compliance
EPA Concern
Proposed SCAPCA Action to Address Concern
Schedule for SCAPCA
Action to Address
Concern
2018 Status of EPA
Concern
1. Permits need to
clarify when a
deviation occurs when
monitored parameters
are outside of the
acceptable ranges
and SCAPCA needs
to add recordkeeping
so each event of
operation outisde the
acceptable range is
documented
In the future, SCAPCA will clarify when a deviation
occurs and add recordkeeping so that each event
of operation outside of an acceptable range is
documented.
SCAPCA will implement
action in all new and
renewal permits drafted
from this point forward
SRCAA attempts to
clarify when a deviation
occurs when monitored
parameters are outside
of acceptable ranges.
SCAPCA
EPA TITLE V PROGRAM REVIEW ACTION PLAN
PAGE 5 OF 7
11/9/2018
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G. Resources and Internal Management Support
EPA Concern
Proposed SCAPCA Action to Address Concern
Schedule for SCAPCA
Action to Address
Concern
2018 Status of EPA
Concern
1. Possible confusion
related to the
allocation of permitting
staff labor cost to Title
V and non-Title V
budgets
This issue has been addressed with SCAPCA's
recently revised Title V fee regulations. See
SCAPCA Regulation I, Section 10.06 for the
revised fee regulation.
Already been addressed
Already addressed
2. Possible confusion
related to allocation of
Title V penalties
received by SCAPCA
SCAPCA has never used Title V penalties as Title
V revenues and will not do so in the future.
N/A
Never has been an issue.
3. SCAPCA's Title V
permit engineer has
had limited access to
Title V training.
SCAPCA is committed to providing access to
pertinent training for all Title V staff. However, we
have not seen much in the way of Title V training
in recent years in any proximate population
centers. We will watch for future training offered.
N/A
SRCAA has offered Title
V training to all staff. Both
permit engineers and the
inspector attended EPA's
most recent Title V
workshop.
4. SCAPCA's Title V
costs have exceeded
revenues for a
number of years.
This issue has been addressed by SCAPCA's
recently revised fee regulations. In the revised
fee regulation, all future Title V costs will be
recovered, and past program deficit will be
recovered over the next 10 year period.
Already been addressed
Already been addressed.
No deficit to Title V
program.
I. Document Review (Rules/Forms/Guidance)
EPA Concern
Proposed SCAPCA Action to Address Concern
Schedule for SCAPCA
Action to Address
Concern
2018 Status of EPA
Concern
1. SCAPCA updates
their Title V rates
periodically, but has
not submitted their
SCAPCA will send rule revisions that are directly
contained in the SIP to EPA for review and
approval. However, we are not aware of any
requirement to send rules, such as routine fee
N/A
Three rules revisions to
Title V fees have been
done since 2003.
SCAPCA
EPA TITLE V PROGRAM REVIEW ACTION PLAN
PAGE 6 OF 7
11/9/2018
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revisions to EPA for
review and approval
adjustments, to EPA for review and approval.
2. On Form A-1 of
AOP renewal
application, questions
10 and 11 imply that a
permittee has a
choice regarding
whether off-permit
changes would be
integrated into the
permit.
SCAPCA will change this item in our AOP renewal
application to ensure that all off-permit changes
made during the prior permit term will be
incorporated into the renewal permit.
SCAPCA will implement
action in all renewal
applications sent out from
this point forward
Change made to AOP
renewal application.
3. Form A-1 of AOP
renewal application
and the instructions
form omit the
information that
ambient air quality
data and air emissions
data are not entitled to
confidential treatment.
SCAPCA will revise the AOP renewal application
to cite the state law on confidentiality and clarify
that ambient air quality data and air emissions
data are not entitled to confidential treatment.
SCAPCA has always ensured that any information
claimed confidential by an applicant meets the
state law on confidentiality (RCW 70.94.205) and
does not include ambient air quality data and/or
air emissions data.
SCAPCA will implement
action in all renewal
applications sent out from
this point forward
Changes made to AOP
renewal application.
4. EPA would prefer
that SCAPCA's
renewal application
focus on requirements
for claiming
information as
confidential under
State law, rather than
federal law.
SCAPCA will revise the instructions to Form A-1 in
the AOP renewal application to refer to the state
confidential law, rather than the federal law.
SCAPCA will implement
action in all renewal
applications sent out from
this point forward
Changes made to AOP
renewal application.
SCAPCA
EPA TITLE V PROGRAM REVIEW ACTION PLAN
PAGE 7 OF 7
11/9/2018
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July 20, 2007
Richard Albright, Director
Office of Air, Waste and Toxics
United States EPA Region 10
1200 Sixth Avenue, AWT-107
Seattle, WA 98101
RE: SRCAA response to letter dated June 27, 2007
Dear Mr. Albright:
The Spokane Regional Clean Air Agency (SRCAA) has received your letter, dated June 27,
2007, describing the remaining outstanding issues regarding our Action Plan in response to the
Title V Program Review Final Report. To address the remaining issues, SRCAA offers the
following responses:
Testing requirements that allow alternative test methods
In future Air Operating Permits, SRCAA will not include a provision that allows for alternative
test methods.
2018 Status
SRCAA does not include provisions that allow for alternative test methods.
Notice of Construction fees
Currently, SRCAA does track the time and costs associated with the Notice of Construction
(NSR) program for the Title V sources. These costs are paid by the Title V sources as part of
their annual fee under the SRCAA Time Fee. Therefore, it is not entirely true to state that funds
collected under Title V are used to develop NSR permits, since the sources do pay for the time
associated with the NSR permit.
However, in order to make the NSR fees completely separate from the Title V monies, SRCAA
will amend our regulations to stipulate that the NSR fee schedule that currently only applies to
non-Title V sources will apply to all sources (including Title V sources). Due to current Title V
workloads (5 renewal applications currently in process) and the resources necessary to perform
a regulation revision, SRCAA will not be able to initiate the regulation revision until 1st Quarter
2008. We trust EPA concurs that Title V permitting work which directly impacts air quality
should take precedence over administrative issues like regulation amendments.
2018 Status
The NSR fees were separated from the Title V fees / monies through the fee revision completed
by SRCAA in 2008.
If you have any questions about this letter, please contact April Westby of my staff at (509) 477-
4727, ext. 105 or awestby@spokanecleanair.org
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Sincerely,
SPOKANE REGIONAL CLEAN AIR AGENCY
William Dameworth
Director
Cc: Paul Koprowski, EPA Acting Washington Air Coordinator
Pat Nair, EPA Boise Office
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PROPOSED REVISIONS TO SCAPCA AIR
OPERATING PERMIT FEES
FACT SHEET
Summary of Proposed Changes:
• New Three-Part Annual Fee
1) Base Fee of $3,000 (same as current)
2) Emission Fee of $31.11 per ton of emissions from previous calendar year (same as
current)
3) SCAPCA Time Fee (new fee), which will cover the remaining AOP program costs
not covered by the base fee and emission fee totals. The SCAPCA time fee will be
calculated for each source by multiplying the remaining AOP program costs (those
not covered by the base fee and emission fee totals) by the percentage of time that
SCAPCA staff spent on the source during the year. SCAPCA will use detailed time
accounting records to track time spent on each source to calculate the percentage of
time spent on that source.
• Notice of Construction (NOC) Fees Not Applicable to AOP Sources
AOP Sources will no longer be required to pay fees related to Notice of Construction
review (e.g., NOC filing fee, SEPA filing fee, NOC review fee, etc.). These fees will be
included as part of the SCAPCA Time Fee.
• Shortfall Recovery Fee for Next 10 Years
Per EPA direction, SCAPCA must recover the past cumulative AOP program deficit,
which has accrued over the past 12 years. To recover this deficit, which is expected to
total -$45,000 at the end of this year, SCAPCA is proposing to institute a "Shortfall
Recovery Fee" as part of the annual fee for the next ten years. The "Shortfall Recovery
Fee" will spread recovery of the program deficit over a ten period. Each year, from
2006-2015, an equal fee will be assessed to the sources subject to the AOP program
during that year. With the current number of AOP sources, SCAPCA estimates that
each source will be charged ~$500 per year for the next ten years to recover the past
program deficit.
2/27/06
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Notice of Public Comment Period and Public Hearing for Proposed Revisions
To SCAPCA Regulation I, Sections 10.06 & 10.07
Air Operating Permit Fees
Date: July 27, 2006
To: Air Operating Permit Sources and Other Interested Parties
From: April Westby, Environmental Engineer
Summary of Proposed Revisions
The Spokane County Air Pollution Control Authority (SCAPCA) has proposed
revisions to SCAPCA Regulation I, Article X, Section 10.06 - Registration and
Operating Permit Fees For Air Contaminant Sources and SCAPCA Regulation I,
Article X, Section 10.07 - Application and Permit Fees for Notice of Construction
and Application for Approval and for Notice of Intent to Install and Operate a
Temporary Stationary Sources. The purpose of the revisions is to achieve full cost
recovery of SCAPCA's Air Operating Permit (AOP) Program, as mandated by
Federal and State Clean Air Acts. The proposed fee changes will allow SCAPCA to
recover all future Air Operating Permit costs (i.e., achieve full cost recovery) as
well as recover the past Air Operating Permit program deficit (-$45,000) accrued
over the past 10 years. Changes to the existing rules include:
1. Addition of SCAPCA time fee as part of the annual fee paid by sources that are
subject to the AOP program during any portion of the calendar year;
2. Addition of Program deficit recovery fee as part of the annual fee paid by
sources that are subject to the AOP program during any portion of the calendar
year. The Program deficit recovery fee will expire in 2016 when the AOP
program deficit will be zero; and
3. Elimination of Notice of Construction fees for AOP sources.
Proposed Revised Regulations
The proposed revised regulations are available for review on SCAPCA's web-site
at www.scapca.org. To request a hard copy of the revised regulations, please
contact April Westby at alwestby@scapca.org or (509) 477-4727 ext. 105.
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Public Comment Period - Written Comments Requested
SCAPCA would like your written comments on the proposed Air Operating Permit
Fee revisions. Please send written comments on or before September 6. 2006 to:
SCAPCA
Attn: April Westby
1101 W. College, Suite 403
Spokane, WA 99201
Public Hearing Scheduled
A public hearing on the proposed changes to the Air Operating Permit Fees will be
held during September's Board Meeting. At the public hearing, after public
comments are heard, SCAPCA's Board of Directors will decide whether or not to
adopt the proposed changes.
Date: September 7, 2006
Time: 9:30 am
Location: Spokane County Public Works Building
Lower Level Hearing Room
1206 W. Broadway
Spokane, WA 99201
More Information / Questions
For additional information, please contact April Westby at alwestby@scapca.org or
(509) 477-4727, ext. 105.
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A RESOLUTION AMENDING REGULATION I, ARTICLE X, )
SECTION 10.06 & 10.07 - AIR OPERATING PERMIT FEES ) RESOLUTION 06-16
WHEREAS, pursuant to the provisions of the Washington Clean Air Act, Chapter 70.94 RCW, the Spokane County
Air Pollution Control Authority (SCAPCA) was created as a municipal corporation of the State of Washington; and
WHEREAS, RCW 70.94.141 authorizes the Board of an activated authority to adopt, amend and repeal its own rules
and regulations, and
WHEREAS, the 1990 amendments to the Federal Clean Air Act (42 USC 7401 et. seq.) mandate a nationally uniform
permit program for major stationary sources of air pollution, including a system of fees, sufficient to recover all direct and
indirect program costs, and
WHEREAS, the Washington Clean Air Act (Ch. 70.94 RCW) requires the system of fees to fully recover and not
exceed the program costs, and
WHEREAS, RCW 70.94.162 authorizes SCAPCA to assess and collect fees sufficient to cover the direct and indirect
costs of implementing an operating permit program; and SCAPCA has received delegated authority to administer the air
operating permit program in Spokane County, and
WHEREAS, an amendment to the regulation is necessary to achieve full cost recovery in future years and recover past
program deficit of ~$ 19,000 over the next ten years;
NOW THEREFORE, BE IT RESOLVED that the Board of Directors of SCAPCA, hereby adopts the amendments to
SCAPCA Regulation I, Article X Sections 10.06 and 10.07 Air Operating Permit Fees; attached hereto as Appendix A.
DATED THIS 7TH DAY OF SEPTEMBER 2006.
SPOKANE COUNTY AIR POLLUTION CONTROL AUTHORITY
ATTEST:
WILLIAM O. DAMEWORTH, DIRECTOR
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APPENDIX A
RESOLUTION 06-16
AMENDATORY SECTION
REGULATION I, ARTICLE X, SECTIONS 10.06 & 10.07
ARTICLE X
SECTION 10.06 REGISTRATION AND OPERATING PERMIT FEES FOR AIR CONTAMINANT
SOURCES
A. Each source required by Article IV, Section 4.01 to be registered, each air operating
permit source, and each source required by Article V, Section 5.02 to obtain an approved
Notice of Construction and Application for Approval is subject to an annual fee for each
calendar year, or portion of each calendar year, during which it operates. The owner or
operator shall pay the fee, pursuant to the requirements in Section 10.02. Fees received
pursuant to the registration program or the operating permit program shall not exceed the
actual costs of program administration.
B. The annual fee for each source shall be determined as follows:
1. For sources that are not subject to Section 10.06.B.3, 4, or 5. of this Regulation
and which emit less than 5 tons per year of criteria and toxic air pollutants:
a. a flat fee of $160; and
b. a $30 fee for each stack and other emission point, not to exceed $600;
and
c. an emission fee of $20 per ton of each criteria and toxic air pollutant; and
d. an additional fee of $150 for each source which operated at least one
incinerator or burn out oven during the registration period; and
e. an additional fee of $100 if the source is required by the Authority to
submit an annual emissions inventory to the Washington Emission Data
System (WEDS).
2. For sources that are not subject to Section 10.06.B.3, 4, or 5. of this Regulation
and which emit 5 tons or more per year of criteria and toxic air pollutants, but less
than 100 tons per year of any one criteria pollutant:
a. a flat fee of $215; and
b. a $30 fee for each stack and other emission point, not to exceed $600;
and
c. an emission fee of $20 per ton of each criteria and toxic air pollutant; and
d. an additional fee of $150 for each source which operated at least one
incinerator or burn out oven during the registration period; and
-------
e.
an additional fee of $100 if the source is required by the Authority to
submit an annual emissions inventory to the Washington Emission Data
System (WEDS).
3. For facilities, where the dispensing of gasoline is the only registered emission
point, and which are not subject to Section 10.06.B.4 of this Regulation, a flat fee
of $165.
((3))4. For ((air operating permit sources, a share of the assessment by Ecology,
pursuant to RCW 70.94.162(3), determined according to Section 10.06.D of this
Regulation, plus:)) sources that are subject to the air operating permit (AOP)
program during any portion of the calendar year:
a. ((aw)) Annual base fee of $3,000; ((afld))
b. ((aft)) Emission fee of $31.11 per ton of actual emissions from the previous
calendar year;
c. SCAPCAtime fee, as determined by the following formula:
(Hj +Hg)xRPC
TFj =
Hx
Where.
TFi is the SCAPCA time fee for AOP source. I;
Hi is the total SCAPCA staff hours spent on AOP source. I;
Hg is the total general hours SCAPCA staff spent on the AOP program
divided by the total number of sources subject to the AOP program during
any portion of the calendar year;
RPC is the remaining SCAPCA AOP program cost, calculated by subtracting
the sum of the Section 10.06.B.4.a and b. fees from the total SCAPCA AOP
program costs; and
Ht is the total number of hours SCAPCA staff spent on the AOP program,
including total time spent on the AOP sources and general hours spent on
the AOP program.
Note: Hi. Hg. Ht. and RPC are for the most recent SCAPCA fiscal year.
Note: Hi. Hg. and Ht are obtained from SCAPCA time accounting records.
d. Program deficit recovery fee, as determined by the following formula:
Remaining Program Deficity Ei(y-i)
PDRFi 2006^2015 = - x —
(2016-y) Et (y - i )
Where,
PDRFi is the program deficit recovery fee assessed during year "v" (from
2006-2015) to each AOP source. I. that operated during any portion of the
calendar year "v";
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Remaining Program Deficitv is the total cumulative funding deficit for
SCAPCA's AOP program at the end of year "v";
"v" is the year, beginning in year 2006 and ending in year 2015;
Ei is the total (in tons) of actual emissions from AOP source. I. during the
calendar year prior to year "v" (v-1); and
Et is the sum (in tons) of the actual emissions from all AOP sources during
the calendar year prior to year "v" (v-1).
Note: The program deficit recovery fee will expire in 2016 when the AOP
program deficit will be zero.
e. A share of the assessment by Ecology pursuant to RCW 70.94.162(3), as
determined by the following formula:
j _ FixAe
Ft
Where.
I is the individual share of the assessment:
Fi is the total individual fee assessed pursuant to Section 10.06.B.4.a., b.. c.. and
d. of this Regulation:
Ae is the total Ecology assessment pursuant to RCW 70.94.162(3:, and
Ft is the sum of all the individual fees assessed pursuant to Sections
10.06.B.4.a., b.. c.. and d. of this Regulation.
((4))5. For affected units under Section 404 of the Federal Clean Air Act (42 USC 7401
et seq):
a. A fee of $50 per hour of time expended in carrying out the fee eligible
activities specified in RCW 70.94.; and
b . A share of the assessment by Ecology pursuant to RCW 70.94.162(3').
as determined by the following formula:
j _ FjxAe
Ft
Where.
I is the individual share of the assessment;
Fi is the total individual fee assessed pursuant to Section 10.06.B.5.a. of this
Regulation;
Ae is the total Ecology assessment pursuant to RCW 70.94.162(3'); and
Ft is the sum of all the individual fees assessed pursuant to Sections
10.06.B.5.a. of this Regulation.
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((& a share of the assessment by Ecology, pursuant to RCW 70.94.162(3),
determined pursuant to Section 10.06.D of this Regulation.
& For facilities, where the dispensing of gasoline is the only registered emission
point, and which are not subject to Section 10.06.B.3 of this Regulation, a flat fee
of $165.
Q-. The Board shall annually review the fee schedule for air operating permit sources and
projected costs to implement the requirements of RCW 70.94.161 and determine if the
total projected fee revenue to be collected pursuant to this Section is sufficient to recover
program costs. Such review shall include opportunity for public review and comment on
the projected costs and any changes to the operating permit fee schedule. Accordingly,
the Authority shall account for program costs, including employee costs and overhead. If
the Board determines that the total projected fee revenue is either significantly excessive
or deficient for this purpose, then the Board shall amend the fee schedule to more
accurately recover program costs.
& Individual shares of the assessment pursuant to RCW 70.94.162(3) shall be determined
by the following formula:
I ~ Ft x Ae
-R:
Where,
I is the individual share of the assessment, and
Ei is the individual fee assessed pursuant to Section 10.06.B.3, or 4. of this
Regulation, and
Ae is the total assessment pursuant to RCW 70.94.162(3), and
Ei is the sum of all the individual fees assessed pursuant to Sections 10.06.B.3,
or 4. of this Regulation.))
SECTION 10.07 APPLICATION AND PERMIT FEES FOR NOTICE OF CONSTRUCTION AND
APPLICATION FOR APPROVAL AND FOR NOTICE OF INTENT TO
INSTALL AND OPERATE A TEMPORARY STATIONARY SOURCE
The fees contained in Section 10.07 do not apply to air operating permit sources.
A. Filing Fee - For each project required by Article V to file a Notice of Construction and
Application for Approval (NOC) or a Notice of Intent to Install and Operate a Temporary
Stationary Source, the applicant shall pay a filing fee of $150 at the time of filing the
application.
B. Project Review Fee - IN ADDITION to the filing fee provided in Section 10.07.A, the
applicant shall pay a fee, according to the following:
1
Equipment fee - Sources for which an application is made for one or more
emission points under one Notice of Construction or Notice of Intent to Install and
Operate a Temporary Stationary Source application, as allowed in Section
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5.02.G, the equipment fee, for each emissions unit and/or air pollution control
system being installed or modified, shall be as follows:
a. Fuel Burning Equipment With or Without Air Pollution Control Equipment:
Design Input Size (MMBtu/hr) Fee
.4
<
5
$200
5
<
10
$250
10
<
20
$300
20
<
50
$350
50
<
100
$400
100
<
250
$500
250
<
500
$650
500
<
UP
$850
b. Refuse Burning Equipment Including Air Pollution Control Equipment:
Capacity (ton/day) Fee
0 <
12
$1,000
12 <
250
$1,500
250 <
UP
$2,500
c. Process Equipment and/or Air Pollution Control Equipment or
Uncontrolled Process Equipment:
Actual ft3/min
Fee
0 <
5,000
$150
5,000 <
20,000
$250
20,000 <
50,000
$350
50,000 <
100,000
$450
100,000 <
250,000
$550
250,000 <
500,000
$650
500,000 <
UP
$800
d. Gasoline dispensing facilities:
Equipment Being Installed Fee
Annual facility gasoline
throughput of less than 1.5 million gallons $150
Annual facility gasoline
throughput of 1.5 million gallons or greater $250
e. For sources not included in the above categories, an hourly fee of $50.00
per hour of time expended in project review.
2. Significant emissions review fee - In addition, except for projects subject to an
equipment fee, pursuant to Section 10.07.B.1 .e. above, for any new or modified
source of air pollution to be constructed and anticipated to produce significant
emissions, as defined in Article I, Section 1.04. of this Regulation, a significant
emissions review fee of $250.
3. Toxic air pollutant review fee - In addition, except for projects subject to an
equipment fee, pursuant to Section 10.7.B.1 .e. above, for any new or modified
source of air pollution which requires review pursuant to Chapter 173-460 WAC,
a toxic air pollutant review fee. For sources with one or more emission points
under one Notice of Construction application, as allowed in Section 5.02.G, a
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separate toxic air pollutant review fee applies to each emissions unit, or each
group of like-kind emissions units, being installed or modified. A group of
emissions units shall be considered as like-kind if the same set of emission
calculations can be used to characterize emissions from each of the emissions
units. The toxic air pollutant review fee shall be as follows:
a. For a new or modified source using WAC 173-460-080(2)(e), Small
Quantity Emission Rates, to demonstrate that ambient impacts are
sufficiently low to protect human health and safety, as required WAC
173-460-070 & WAC 173-460, an additional charge of $100;
b. For a new or modified source using dispersion screening models (e.g.,
EPA SCREEN orTSCREEN) under WAC 173-460-080(2)(c) to
demonstrate that ambient impacts are sufficiently low to protect human
health and safety, as required WAC 173-460-070, an additional charge
of $150;
c. For a new or modified source using more refined dispersion models
(e.g., EPA ISC3) under WAC 173-460-080(2)(c) to demonstrate that
ambient impacts are sufficiently low to protect human health and safety,
as required WAC 173-460-070, an additional charge of $400; or
d. For a new or modified source using a second tier analysis under WAC
173-460-090 or a risk management decision under WAC 173-460-100 to
demonstrate that ambient impacts are sufficiently low to protect human
health and safety, as required WAC 173-460-070, an additional charge
of$1000.
4. NSPS Review Fee - In addition, except for projects subject to an equipment fee,
pursuant to Section 10.07.B.1 .e. above, for any new or modified source of air
pollution, subject to a standard under WAC 173-400-115 (NSPS), an additional
charge as follows:
a. If subject to 40 CFR Part 60, Subpart Dc, Standards of Performance for
Small Industrial-Commercial-lnstitutional Steam Generating Units, with
only natural gas as a fuel, an additional charge of $50;
b. If subject to 40 CFR Part 60, Subpart Dc, Standards of Performance for
Small Industrial-Commercial-lnstitutional Steam Generating Units, using
fuels other than solely natural gas, an additional charge of $100;
c. If subject to 40 CFR Part 60, Subpart I, Standards of Performance for
Hot Mix Asphalt Facilities, an additional charge of $100;
d. If a volatile organic liquid storage tank subject to 40 CFR § 60.110b(b) or
(c), no additional charge;
e. If subject to 40 CFR Part 60, Subpart OOO, Standards of Performance
for Nonmetallic Mineral Processing Plants, no additional charge; and
f. If subject to a subpart of 40 CFR Part 60, other than those covered in a.
through d. above, an additional charge of $250.
5. NESHAP Review Fee - In addition, except for projects subject to an equipment
fee, pursuant to Section 10.07.B.1 .e. above, for any new or modified source of air
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pollution, subject to a standard under WAC 173-400-075 (NESHAP), an
additional charge as follows:
a. If subject to 40 CFR Part 63, Subpart M, National Perchloroethylene Air
Emissions Standards for Dry Cleaning Facilities, and/or WAC 173-400-
075(6), Emission Standards for Perchloroethylene Dry Cleaners, no
additional charge;
b. If subject to 40 CFR Part 63, Subpart N, National Emission Standards for
Chromium Emissions From Hard and Decorative Chromium
Electroplating and Chromium Anodizing Tanks, an additional charge of
$100;
c. If subject to 40 CFR Part 63, Subpart T, National Emission Standards for
Halogenated Solvent Cleaning, an additional charge of $150; and
d. If subject to a subpart of 40 CFR Part 63, other than those covered in a
through c. above, an additional charge of $250.
6. Integrated Review Fee - In addition, for integrated review of a Notice of
Construction and Application for Approval, as allowed under Section 5.02.J of
this Regulation, an additional charge of $250.
C. Change in Condition Fee - Sources for which application is made for a change in
conditions pursuant to Section 5.10.C of this Regulation, the fee shall be one half the
current fee for a Notice of Construction and Application for Approval or a Notice of Intent
to Install and Operate a Temporary Stationary Source for that type of source, including
the filing fee, according to Section 10.07.A, and the applicable fees, according to Section
10.07.B, or $350, whichever is less.
D. Compliance Investigation Fee - Where a compliance investigation is conducted pursuant
to Section 5.12 of this Regulation, the compliance investigation fee shall be $300 per
emissions unit, or group of like-kind emissions units, being installed or modified. A group
of emissions units shall be considered as like-kind if the same set of emission
calculations can be used to characterize emissions from each of the emissions units.
E. SEPA Review Fee - Where review of an Environmental Impact Statement (EIS),
Environmental Checklist, or an Addendum to, or adoption of, an existing environmental
document pursuant to the State Environmental Policy Act (SEPA) Chapter 197-11 WAC
is required, in association with a Notice of Construction and Application for Approval or a
Notice of Intent to Establish a Temporary Stationary Source, the applicant shall pay a
SEPA or EIS review fee of $50 per hour or $125, whichever is greater. The applicant
shall pay a partial SEPA review fee of $125, at the time of submittal of the EIS or SEPA.
The Authority will bill the owner, operator, or applicant for the remainder of the SEPA or
EIS review fee after a threshold determination has been made and/or a preliminary
determination of the Notice of Construction has been issued.
F. Complex Project Review Fee -
1. The Control Officer may notify the applicant in writing that, due to the complexity
of the application, the permit processing fees will be based on the actual hours
spent by the Authority staff in evaluating and verifying the proposed project's
compliance with applicable federal, state, and local rules and regulations. The
complexity fee applies to Notice of Construction and Application for Approval
orders and Notice of Intent to Establish a Temporary Stationary Source
permissions to operate.
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2. The complexity fee assessed shall be $50 per hour and shall not exceed the
actual cost of processing and reviewing the proposed project. This complexity
fee may include, but is not limited to, costs associated with planning meetings
and/or design evaluations, that are related to the proposed project, prior to actual
submission of a complete application.
3. The complexity of a permit shall be determined by dividing the usual fee in
Section 10.07.B.1.a - d. by $50 per hour. If this number is less than the actual
hours spent in review, the Authority may elect to assess a Complex Project
Review Fee instead of assessing the fee according to the schedule in Section
10.07.B.1.a. - d. The actual review time shall not include the time associated
with review of an environmental checklist or environmental impact statement.
These fees are assessed separately under Section 10.07.E.
4. The applicant may avoid being subject to a Complex Project Review Fee by
providing additional information with the application that reduces the cost to the
Authority in reviewing the application to a level consistent with the fee schedule
in Section 10.07.B.1a - d.
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Poninnal
1101 W. College Ave.. Suite 403. Spokane. WA 99201 ~ (509) 477-4727 ~ Fax (509) 477-6828 ~ www.spokanecleanair.org
A RESOLUTION AMEN DIN G REGULATION I, ARTICLE X, )
SECTION 10.06 & 10.07 - AIR OPERATING PERMIT FEES ) RESOLUTION 08-18
WHEREAS, pursuant to the provisions of the Washington Clean Air Act, Chapter 70.94 RCW, the
Spokane Regional Clean Air Agency (SRCAA)was created as a municipal corporation of the State of Washington;
and
WHEREAS, RCW 70.94.141 authorizes the Board of an activated authority to adopt, amend and repeal its
own ailes and regulations, and
WHEREAS, the 1990 amendments to the Federal Clean Air Act (42 USC 7401 et. seq.) mandate a
nationally uniform permit program for major stationary sources of air pollution, including a system of fees,
sufficient to recover all direct and indirect program costs, and
WHEREAS, the Washington Clean Air Act (Ch. 70.94 RCW) requires the system of fees to fully recover
and not exceed the program costs, and
WHEREAS, RCW 70.94.162 authorizes SRCAA to assess and collect fees sufficient to cover the direct
and indirect costs of implementing an operating permit program; and SRCAA has received delegated authority to
administer the air operating permit program in Spokane County,
WHEREAS, an amendment to the regulation is necessary to achieve full cost recovery in future years and
recover past program deficit of -$50,000, and
WHEREAS, an amendment to the regulation is necessary to separate Notice of Construction review fees
from air operating permit annual fees;
NOW THEREFORE, BE IT RESOLVED that the Board of Directors of SRCAA, hereby adopts the
amendments to SRCAA Regulation I, Article X Sections 10.06 and 10.07 Air Operating Permit Fees; attached
hereto as Appendix A.
DATED THIS 3RD DAY OF JULY 2008
SPOKANE REGIONAL CLEAN AIR AGENCY
Clean Al Agency
Jeffrey Corkill, Chair
Bonnie Mager
ATTEST:
William Dameworth, Director
Melissa Ahern
Edward Crockett
Rose Dempsey
working with you for clean air
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Appendix A - Resolution 08-18
AMENDATORY SECTIONS
REGULATION I, ARTICLE VI, SECTION 10.06 & 10.07
SECTION 10.06 REGISTRATION AND OPERATING PERMIT FEES FOR AIR CONTAMINANT
SOURCES
A. Each source required by Article IV, Section 4.01 to be registered, each air operating permit source, and
each source required by Article V, Section 5.02 to obtain an approved Notice of Construction and
Application for Approval is subject to an annual fee for each calendar year, or portion of each calendar
year, during which it operates. The owner or operator shall pay the fee, pursuant to the requirements in
Section 10.02. Fees received pursuant to the registration program or the operating permit program shall
not exceed the actual costs of program administration.
B. The annual fee for each source required by Article IV, Section 4.01 to be registered and that is not subject
to Section 10.06.C. of this Regulation shall be determined by adding all of the applicable fees below;
Registration Fee Categories
Fee
Fee Applicability
Facility Fee A
Per the Fee Schedule
Per Source
Emissions Fee B
Per the Fee Schedule
Per Ton
Emission Point Fee c
Per the Fee Schedule
Per Stack/Point
Burn Out Oven/Incinerator Fee D
Per the Fee Schedule
Per Source
Synthetic Minor Fee E
Per the Fee Schedule
Per Source
WEDS Fee F
Per the Fee Schedule
Per Hour
a. Each source is subject to the fee listed.
b. The additional fee listed applies to each ton (rounded to the nearest one-tenth of a ton) of
each criteria and toxic air pollutant emitted.
c. The additional fee applies to each stack and other emission points. For gasoline stations,
each gasoline tank vent is an emission point.
d. The additional fee listed applies to each source which operated at least one incinerator or
burn out oven during the registration period.
e. The additional fee listed applies to each Synthetic Minor source as defined in SRCAA
Regulation I, Article I, Section 1.04.
f. The additional fee listed applies to each source required by the Authority to submit an
annual emissions inventory for entry into the Washington Emission Data System (WEDS).
SRCAA staff time spent processing and reviewing WEDS will be tracked in 15 minute
increments and charged at the hourly rates provided above.
2. The Board shall periodically review the fee schedule for registered sources and determine if the
total projected fee revenue to be collected pursuant to this Section is sufficient to fully recover
program costs. Any proposed fee revisions shall include opportunity for public review and
comment. Accordingly, the Agency shall account for program costs, including employee costs and
Article X - Page 2
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Appendix A - Resolution 08-18
overhead. If the Board determines that the total projected fee revenue is either significantly
excessive or deficient for this purpose, then the Board shall amend the fee schedule to more
accurately recover program costs.
C. The annual fee for each air operating permit source shall be determined as follows:
1. The Board shall periodically review the fees for air operating permit sources and determine if the
total projected fee revenue to be collected pursuant to this Section is sufficient to fully recover
program costs. Any proposed fee revisions shall include opportunity for public review and
comment. Accordingly, the Agency shall account for program costs, including employee costs and
overhead. If the Board determines that the total projected fee revenue is either significantly
excessive or deficient for this purpose, then the Board shall amend the fees to more accurately
recover program costs.
2. For sources that are subject to the air operating permit (AOP) program during any portion of the
calendar year:
a. Annual base fee of $3,000;
b. Emission fee of $31.11 per ton of actual emissions from the previous calendar year;
c. SRCAA time fee, as determined by the following formula:
Tp (Hi+Hg)xRPC
1 ht
Where,
TFiis the SRCAA time fee for AOP source, I;
Hi is the total SRCAA staff hours spent on AOP source, not including time spent on
Notice of Construction application reviews. I;
Hg is the total general hours SRCAA staff spent on the AOP program divided by the total
number of sources subject to the AOP program during any portion of the calendar year;
RPC is the remaining SRCAA AOP program cost, calculated by subtracting the sum of the
Section 10.06.C.2.a and b. fees from the total SRCAA AOP program costs; and
Ht is the total number of hours SRCAA staff spent on the AOP program, including total
time spent on the AOP sources and general hours spent on the AOP program.
Note: Hi, Hg, Ht, and RPC are for the most recent SRCAA fiscal year.
Note: Hi, Hg, and Ht are obtained from SRCAA time accounting records.
d. ((Program deficit recovery foo))AOP Program Cost Correction, as determined by the
following formula:
Article X - Page 3
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Appendix A - Resolution 08-18
Remaining Program Deficity Ei(y-i)
FDRTiy=2006^2015 - ~
(2016-y) Et (y - i )
PCCt = AOP Program Cumulative Deficit or Surplus x Ft
Ft
Where,
PCCt is the AOP Program Cost Correction assessed ((PDRF^is the program deficit
recovery fee assessed during year "y" (from 2006 2015) to each AOP source, I((, that
operated during any portion of the calendar year "y"));
AOP Program Cumulative Deficit or Surplus is the cumulative financial deficit or surplus
for SRCAA's ((Remaining Program Deficity is the total cumulative funding deficit for
SCAPCA's AOP program at the end of the most recent SRCAA fiscal year ((^v-)):
(("y" is the year , beginning in year 2006 and ending in year 2015;))
Ft is the total individual fee assessed pursuant to Section 10.06.C.2.a.. b.. and c.. of this
Regulation; and
Ft is the sum of all the individual fees assessed pursuant to Sections 10.06.C.2.a.. b.. and
c. of this Regulation.
((E{ is the total (in tons) of actual omissions from AOP source, I, during the calendar year
prior to year "y" (y 1); and
¦fe^is the sum (in tons) of the actual omissions from all AOP sources during the calendar
year prior to yoar "y" (y 1).
Noto: The program deficit recovery foo will oxpiro in 2016 when tho AOP program deficit
will bo zero.))
e. A share of the assessment by Ecology pursuant to RCW 70.94.162(3), as determined by
the following formula:
j _ FixAe
Ft
Where,
I is the individual share of the assessment;
Fi is the total individual fee assessed pursuant to Section 10.06.C.2.a., b., and c. ((. and d.))
of this Regulation;
Article X - Page 4
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Appendix A - Resolution 08-18
Ae is the total Ecology assessment pursuant to RCW 70.94.162(3); and
Ft is the sum of all the individual fees assessed pursuant to Sections 10.06.C.2.a., b., and
c.((, and d.)) of this Regulation.
3. For affected units under Section 404 of the Federal Clean Air Act (42 USC 7401 et seq):
a. A fee of (($§0)) $65 per hour of time expended in carrying out the fee eligible activities
specified in RCW 70.94.; and
b. A share of the assessment by Ecology pursuant to RCW 70.94.162(3), as determined by
the following formula:
j _ FixAe
Ft
Where,
I is the individual share of the assessment;
Fi is the total individual fee assessed pursuant to Section 10.06.C.3.a. of this Regulation;
Ae is the total Ecology assessment pursuant to RCW 70.94.162(3); and
Ft is the sum of all the individual fees assessed pursuant to Sections 10.06.C.3.a. of this
Regulation.
SECTION 10.07 APPLICATION AND PERMIT FEES FOR NOTICE OF CONSTRUCTION AND
APPLICATION FOR APPROVAL (NOC) AND FOR NOTICE OF INTENT TO
INSTALL AND OPERATE A TEMPORARY STATIONARY SOURCE (NOI)
((The fees contained in Section 10.07 do not apply to air operating permit sources.))
A. NOC and NOI Fees
1. Base Fee
a. For each project required by Article V to file a NOC or a NOI, the applicant shall pay a
base fee pursuant to the fee schedule. Base fee classes are listed below.
1) Class I - Notice of Intent Permit
Notice of Intent permits for portable stationary sources and temporary stationary
sources include the following:
Article X - Page 5
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Appendix A - Resolution 08-18
Article IV.
Exhibit R
Source/Source Category Description Category
(a) Asphalt plant 15
(b) Concrete batch plant / ready mix plant 22
(c) Rock crusher 36
2) Class II - Simple Notice of Construction Permit
Simple permits generally conform to a template and involve minimal off-site
impact evaluation. They include the following:
Article IV.
Exhibit R
Source/Source Category Description Category
(a) Boiler and other fuel-burning equipment 27
(b) Coffee roaster 20
(c) Concrete batch plant / ready mix plant 22
(d) Dry cleaner 23
(e) Emergency generator 52
(f) Gasoline dispensing facility 28
(g) Lithographic printing / screen printing 9.e.5
(h) Material handling that exhausts > 1,000 acfm 24
(i) Rock crusher 36
(j) Spray booth / surface coating operation 57
(k) Stationary internal combustion engine 53
(1) Sterilizer 9.e.8
(m) Stump / wood waste grinder 54
3) Class III - Standard Notice of Construction Permit
Standard permits generally include those that don't conform to a template and
involve minimal off-site impact evaluation. They include the following:
Article IV.
Exhibit R
Source/Source Category Description Category
(a) Soil and groundwater remediation operation 9.e.7
(b) Burn out oven 43
(c) Chrome plating 35
(d) Incinerator / crematory 31
4) Class IV - Complex Notice of Construction Permit
Article X - Page 6
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Appendix A - Resolution 08-18
Complex permits generally include those that don't conform to a template and
involve more complex off-site impact evaluation. They include the following:
Article IV.
Exhibit R
Source/Source Category Description Category
(a) Asphalt plant 15
(b) Composting 21
(c) Refuse systems 48
(d) Rendering 49
(e) Sewerage systems 50
b. For sources / source categories not listed in Section 10.07.A. 1 .a, above, NOI and NOC
application review will be assigned to Class I, II, II or IV by the Control Officer on a case-
by-case basis.
c. For sources with one or more emission points under one NOC application, as allowed in
Section 5.02.G, a separate base fee applies to each emissions unit, or each group of like-
kind emissions units, being installed or modified. A group of emissions units shall be
considered as like-kind if the same set of emission calculations can be used to characterize
emissions from each of the emissions units.
2. Modification / Revision Fee
a. Equipment Modification Fee
Applicants of sources requesting a change in equipment (e.g., replacement or substantial
alteration of emission control technology) pursuant to Section 5.10.C of this Regulation
shall pay a fee pursuant to the fee schedule.
b. Permit Condition Revision Fee
Applicants of sources requesting a change in conditions pursuant to Section 5.10.C of this
Regulation shall pay a fee pursuant to the fee schedule.
3. Additional Fees (for each application)
a. SEPA Review Fee
Where review of an Environmental Impact Statement (EIS), Environmental Checklist, or
an Addendum to, or adoption of, an existing environmental document pursuant to the State
Environmental Policy Act (SEPA) Chapter 197-11 WAC is required, in association with a
NOC or a NOI, the applicant shall pay a SEPA or EIS review fee pursuant to the fee
schedule.
b. Toxics Review Fee
Article X - Page 7
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Appendix A - Resolution 08-18
For any new source of air pollution which requires review pursuant to Chapter 173-460
WAC, a toxic air pollutant review fee shall be paid. For sources with one or more
emission points under one NOC application, as allowed in Section 5.02.G, a separate toxic
air pollutant review fee applies to each emissions unit, or each group of like-kind
emissions units, being installed or modified. A group of emissions units shall be
considered as like-kind if the same set of emission calculations can be used to characterize
emissions from each of the emissions units. The toxic air pollutant review fee shall be as
follows:
1) Small Quantity Emission Rate (SQER)
For a new source using WAC 173-460-080(2)(e), SQER, to demonstrate that
ambient impacts are sufficiently low to protect human health and safety, as
required WAC 173-460-070 & WAC 173-460, the applicant shall pay a SQER
review fee pursuant to the fee schedule.
2) Dispersion Modeling
For a new source using dispersion screening models (e.g., EPA SCREEN or
TSCREEN) under WAC 173-460-080(2)(c) to demonstrate that ambient impacts
are sufficiently low to protect human health and safety, as required WAC 173-
460-070, the applicant shall pay a dispersion modeling review fee pursuant to the
fee schedule.
3) Advanced Modeling
For a new source using more refined dispersion models (e.g., EPA ISC3) under
WAC 173-460-080(2)(c) to demonstrate that ambient impacts are sufficiently low
to protect human health and safety, as required WAC 173-460-070; or for a new or
modified source using a second tier analysis under WAC 173-460-090 or a risk
management decision under WAC 173-460-100 to demonstrate that ambient
impacts are sufficiently low to protect human health and safety, as required WAC
173-460-070, the applicant shall pay the advanced modeling review fee in the fee
schedule.
New Source Performance Standards (NSPS) Review Fee
Applicants of any new air pollution source subject to WAC 173-400-115 (NSPS) and 40
CFR Parts 60 shall pay a NSPS review fee according to the fee schedule.
National Emission Standard for Hazardous Air Pollutants (NESHAP) Review Fee
Applicants of any new air pollution source subject to WAC 173-400-075 (NESHAP) and
40 CFR Parts 61 and 63 shall pay a NESHAP fee according to the fee schedule.
Best Available Control Technology (BACT) Review Fee
1) Generic BACT
Article X - Page 8
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Appendix A - Resolution 08-18
Where no BACT review is required (e.g., the applicant demonstrates there is an
established and/or recognized BACT standard for the source category type), a
BACT review fee is not applicable.
2) Non-Generic BACT Review
A non-generic BACT review is one where a generic BACT standard is not
applicable and a top-down BACT review is not required. Applicants of any new
air pollution source subject to a non-generic BACT review shall pay a non-generic
BACT review fee according to the fee schedule.
3) Top-Down BACT Review (as described in EPA's Draft New Source Review
Workshop Manual from October 1990 and as summarized below)
A top-down BACT review is one that requires available control technologies be
ranked in descending order of control effectiveness. The most stringent or "top"
control technology is first examined. That control technology is established as
BACT unless the applicant demonstrates, and the ((Authority)) Agency concurs,
that technical considerations, energy, environmental, or economic impacts justify
a conclusion that the most stringent technology is not achievable in for the project
being proposed. If the most stringent control technology is eliminated in this
fashion, the next most stringent control technology is considered, and so on.
Applicants of any new air pollution source subject to a top-down BACT review
shall pay a top-down BACT review fee according to the fee schedule.
B. Payment of Fees
1. At the Time of Application
The base fee shall be paid at the time of application. Review of the application will not commence
until the applicable base fee is received.
2. After Application
a. Payment of Fees for Complete Applications
The Agency will invoice the owner, operator, or applicant for all other applicable fees
without regard to whether the request(s) associated with this section are approved or
denied.
b. Payment of Fees for Incomplete Applications
If an owner, operator, or applicant notifies SRCAA in writing that an incomplete
application will not be completed or cancels the application (i.e., the application is neither
approved or denied), applicable fees for review performed pursuant to A.2 and A. 3 of this
section shall be invoiced. If an application remains incomplete for more than 3 months,
the owner, operator, or applicant shall be invoiced applicable fees for review performed
pursuant to A.2 and A.3 of this section. If review of the application recommences,
applicable review fees apply.
Article X - Page 9
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Appendix A - Resolution 08-18
C. Incomplete Applications
Applications not accompanied by the base fee will be considered incomplete. In addition, if information
requested by the Agency is not provided, the application will be considered incomplete and review of the
application will be suspended. Review of the application will commence, or recommence when
applicable, when all required fees and information requested by the Agency is received. An application
will be cancelled if it remains incomplete for more than 18 months from initial receipt. For review of the
cancelled application to resume, the applicant must pay all outstanding invoice fees, if applicable, and
resubmit the applicable base fee.
D. Compliance Investigation Fee
Where a compliance investigation is conducted pursuant to Section 5.12 of this Regulation, the compliance
investigation fee shall be assessed pursuant to the fee schedule. The fee shall be assessed for each
emissions unit, or group of like-kind emissions units, being installed or modified. A group of emissions
units shall be considered as like-kind if the same set of emission calculations can be used to characterize
emissions from each of the emissions units.
E. Periodic Fee Review
The Board shall periodically review the fee schedule and determine if the total actual fee revenue collected
and projected fee revenue to be collected pursuant to this Section is sufficient to fully recover program
costs. Any proposed fee revisions shall include opportunity for public review and comment. Accordingly,
the Agency shall account for program costs, including employee costs and overhead. If the Board
determines that the total project fee revenue is either significantly excessive or deficient for this purpose,
then the Board shall amend the fee schedule to more accurately recover program costs. In general, fees
will be greater for permits that are typically more complex or take more time to review and process.
Article X - Page 10
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Notice of Public Comment Period and Public Hearing for Proposed Revisions
To SRCAA Regulation I, Sections 10.06 & 10.07
Air Operating Permit Fees
Date: May 19,2008
To: Air Operating Permit Sources and Other Interested Parties
From: April Westby, Environmental Engineer
Summary of Proposed Revisions
The Spokane Regional Clean Air Agency (SRCAA) has proposed revisions to
SRCAA Regulation I, Article X, Section 10.06 - Registration and Operating Permit
Fees For Air Contaminant Sources and SRCAA Regulation I, Article X, Section
10.07 - Application and Permit Fees for Notice of Construction and Application for
Approval and for Notice of Intent to Install and Operate a Temporary Stationary
Sources. The purpose of the revisions is to achieve full cost recovery of SRCAA's
Air Operating Permit (AOP) Program, as mandated by Federal and State Clean Air
Acts. The proposed fee changes will allow SRCAA to recover the past Air
Operating Permit program deficit of $50,000, which is comprised of $16,000
cumulative deficit, which has accrued over the life of the AOP Program and
$34,000 deficit from 2007 due to indirect costs that were not included in the AOP
program costs. In addition, the proposed fee changes separate Notice of
Construction (NOC) fees from the Title V Air Operating Permit annual fees, as
mandated by EPA. Changes to the existing rules include:
1. Addition of "AOP Program Cost Correction" fee as a component to the annual
AOP fee given in SRCAA Regulation I, Section 10.06 C.2, which will reconcile
any AOP program deficit or surplus during the next billing cycle. The "AOP
Program Cost Correction" fee would be divided among the AOP sources
according to the percentage of the total AOP fees that each source's individual
fees comprise. In the 2008 billing, the $50,000 program deficit ($16,000
cumulative deficit + $34,000 deficit from 2007) would be recovered using the
"AOP Program Cost Correction Fee;" and
2. Separation of NOC fees from Title V Air Operating Permit annual fees. SRCAA
Regulation I, Section 10.06 C.2 will be revised to clarify that time spent on NOC
application reviews is not included as part of the annual AOP fee. In addition.
Section 10.07 will be revised so that the NOC fees will apply to AOP sources.
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Proposed Revised Regulations
The proposed revised regulations are available for review on SRCAA's web-site at
www.spokanecleanair.org. To request a hard copy of the revised regulations,
please contact April Westby at awestby@spokanecleanair.org or (509) 477-4727
ext. 105.
Public Comment Period - Written Comments Requested
SRCAA would like your written comments on the proposed Air Operating Permit
Fee revisions. Please send written comments on or before July 2. 2008 to:
SRCAA
Attn: April Westby
1101 W. College, Suite 403
Spokane, WA 99201
Public Hearing Scheduled
A public hearing on the proposed changes to the Air Operating Permit Fees will be
held during July's Board Meeting. At the public hearing, after public comments
are heard, SRCAA's Board of Directors will decide whether or not to adopt the
proposed changes.
Date: July 3, 2008
Time: 9:30 am
Location: Spokane County Public Works Building
Lower Level Hearing Room
1206 W. Broadway
Spokane, WA 99201
More Information / Questions
For additional information, please contact April Westby at
awestbv@spokanecleanair.org or (509) 477-4727, ext. 105.
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Appendix A - Resolution 08-18
AMENDATORY SECTIONS
REGULATION I, ARTICLE VI, SECTION 10.06 & 10.07
SECTION 10.06 REGISTRATION AND OPERATING PERMIT FEES FOR AIR CONTAMINANT
SOURCES
A. Each source required by Article IV, Section 4.01 to be registered, each air operating permit
source, and each source required by Article V, Section 5.02 to obtain an approved Notice of
Construction and Application for Approval is subject to an annual fee for each calendar year, or
portion of each calendar year, during which it operates. The owner or operator shall pay the fee,
pursuant to the requirements in Section 10.02. Fees received pursuant to the registration
program or the operating permit program shall not exceed the actual costs of program
administration.
B. The annual fee for each source required by Article IV, Section 4.01 to be registered and that is
not subject to Section 10.06.C. of this Regulation shall be determined by adding all of the
applicable fees below;
Registration Fee Categories
Fee
Fee Applicability
Facility Fee A
Per the Fee Schedule
Per Source
Emissions Fee B
Per the Fee Schedule
Per Ton
Emission Point Fee c
Per the Fee Schedule
Per Stack/Point
Burn Out Oven/Incinerator Fee D
Per the Fee Schedule
Per Source
Synthetic Minor Fee E
Per the Fee Schedule
Per Source
WEDS Fee F
Per the Fee Schedule
Per Hour
a. Each source is subject to the fee listed.
b. The additional fee listed applies to each ton (rounded to the nearest one-tenth of
a ton) of each criteria and toxic air pollutant emitted.
c. The additional fee applies to each stack and other emission points. For gasoline
stations, each gasoline tank vent is an emission point.
d. The additional fee listed applies to each source which operated at least one
incinerator or burn out oven during the registration period.
e. The additional fee listed applies to each Synthetic Minor source as defined in
SRCAA Regulation I, Article I, Section 1.04.
f. The additional fee listed applies to each source required by the Authority to
submit an annual emissions inventory for entry into the Washington Emission
Data System (WEDS). SRCAA staff time spent processing and reviewing WEDS
will be tracked in 15 minute increments and charged at the hourly rates provided
above.
2. The Board shall periodically review the fee schedule for registered sources and
determine if the total projected fee revenue to be collected pursuant to this Section is
sufficient to fully recover program costs. Any proposed fee revisions shall include
opportunity for public review and comment. Accordingly, the Agency shall account for
program costs, including employee costs and overhead. If the Board determines that the
total projected fee revenue is either significantly excessive or deficient for this purpose,
then the Board shall amend the fee schedule to more accurately recover program costs.
Article X - Page 1
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Appendix A - Resolution 08-18
C. The annual fee for each air operating permit source shall be determined as follows:
1. The Board shall periodically review the fees for air operating permit sources and
determine if the total projected fee revenue to be collected pursuant to this Section is
sufficient to fully recover program costs. Any proposed fee revisions shall include
opportunity for public review and comment. Accordingly, the Agency shall account for
program costs, including employee costs and overhead. If the Board determines that the
total projected fee revenue is either significantly excessive or deficient for this purpose,
then the Board shall amend the fees to more accurately recover program costs.
2. For sources that are subject to the air operating permit (AOP) program during any portion
of the calendar year:
a. Annual base fee of $3,000;
b. Emission fee of $31.11 per ton of actual emissions from the previous calendar
year;
c. SRCAA time fee, as determined by the following formula:
Tp (Hi+Hg)xRPC
1 ht
Where,
TFi is the SRCAA time fee for AOP source, I;
Hi is the total SRCAA staff hours spent on AOP source, not including time spent
on Notice of Construction application reviews. I;
Hg is the total general hours SRCAA staff spent on the AOP program divided by
the total number of sources subject to the AOP program during any portion of the
calendar year;
RPC is the remaining SRCAA AOP program cost, calculated by subtracting the
sum of the Section 10.06.C.2.a and b. fees from the total SRCAA AOP program
costs; and
Ht is the total number of hours SRCAA staff spent on the AOP program,
including total time spent on the AOP sources and general hours spent on the
AOP program.
Note: Hi, Hg, Ht, and RPC are for the most recent SRCAA fiscal year.
Note: Hi, Hg, and Ht are obtained from SRCAA time accounting records.
d. ((Program deficit recovery fee^AOP Program Cost Correction, as determined by
the following formula:
Remaining Program Deficity Ei(y-i)
PDRFi 2006^2015 - ~, r
(2016 —y) Ei(y-i)
Article X - Page 2
-------
Appendix A - Resolution 08-18
PCCi = AOP Program Cumulative Deficit or Surplus x Fi
Ft
Where,
PCCi is the AOP Program Cost Correction assessed ((PDRFiis the program
deficit recovery fee assessed during year "y" (from 2006-2015) to each AOP
source, l((, that operated during any portion of the calendar year "y"));
AOP Program Cumulative Deficit or Surplus is the cumulative financial deficit or
surplus for SRCAA's ((Remaining Program Deficit* is the total cumulative funding
deficit for SCAPCA's AOP program at the end of the most recent SRCAA fiscal
year ((V1));
(("y" is the year, beginning in year 2006 and ending in year 2015;))
Fi is the total individual fee assessed pursuant to Section 10.06.C.2.a., b.. and c..
of this Regulation; and
Ft is the sum of all the individual fees assessed pursuant to Sections
10.06.C.2.a., b.. and c. of this Regulation.
((& is the total (in tons) of actual emissions from AOP source, I, during the
calendar year prior to year "y" (y-1); and
EtUs the sum (in tons) of the actual emissions from all AOP sources during the
calendar year prior to year "y" (y-1).
Note: The program deficit recovery fee will expire in 2016 when the AOP
program deficit will be zero.))
e. A share of the assessment by Ecology pursuant to RCW 70.94.162(3), as
determined by the following formula:
j _ FixAe
Ft
Where,
I is the individual share of the assessment;
Fi is the total individual fee assessed pursuant to Section 10.06.C.2.a., b., and c.
((, and d.)) of this Regulation;
Ae is the total Ecology assessment pursuant to RCW 70.94.162(3); and
Ft is the sum of all the individual fees assessed pursuant to Sections
10.06.C.2.a., b., and c.((. and d.Y) of this Regulation.
3. For affected units under Section 404 of the Federal Clean Air Act (42 USC 7401 et seq):
a. A fee of (($50)) $65 per hour of time expended in carrying out the fee eligible
activities specified in RCW 70.94.; and
Article X - Page 3
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Appendix A - Resolution 08-18
b. A share of the assessment by Ecology pursuant to RCW 70.94.162(3), as
determined by the following formula:
j _ FixAe
Ft
Where,
I is the individual share of the assessment;
Fi is the total individual fee assessed pursuant to Section 10.06.C.3.a. of this
Regulation;
Ae is the total Ecology assessment pursuant to RCW 70.94.162(3); and
Ft is the sum of all the individual fees assessed pursuant to Sections
10.06.C.3.a. of this Regulation.
SECTION 10.07 APPLICATION AND PERMIT FEES FOR NOTICE OF CONSTRUCTION AND
APPLICATION FOR APPROVAL (NOC) AND FOR NOTICE OF INTENT TO
INSTALL AND OPERATE A TEMPORARY STATIONARY SOURCE (NOI)
((The fees contained in Section 10.07 do not apply to air operating permit sources.))
A. NOC and NOI Fees
1. Base Fee
a. For each project required by Article V to file a NOC or a NOI, the applicant shall
pay a base fee pursuant to the fee schedule. Base fee classes are listed below.
1) Class I - Notice of Intent Permit
Notice of Intent permits for portable stationary sources and temporary
stationary sources include the following:
Article IV.
Exhibit R
Source/Source Category Description Category
(a) Asphalt plant 15
(b) Concrete batch plant / ready mix plant 22
(c) Rock crusher 36
2) Class II - Simple Notice of Construction Permit
Simple permits generally conform to a template and involve minimal off-
site impact evaluation. They include the following:
Article IV.
Exhibit R
Source/Source Category Description Category
(a) Boiler and other fuel-burning equipment 27
Article X - Page 4
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Appendix A - Resolution 08-18
(b)
Coffee roaster
20
(c)
Concrete batch plant / ready mix plant
22
(d)
Dry cleaner
23
(e)
Emergency generator
52
(f)
Gasoline dispensing facility
28
(g)
Lithographic printing / screen printing
9.e.5
(h)
Material handling that exhausts > 1,000 acfm
24
(i)
Rock crusher
36
(j)
Spray booth / surface coating operation
57
(k)
Stationary internal combustion engine
53
(I)
Sterilizer
9.e.8
(m)
Stump / wood waste grinder
54
3) Class III - Standard Notice of Construction Permit
Standard permits generally include those that don't conform to a
template and involve minimal off-site impact evaluation. They include
the following:
Article IV,
Exhibit R
Source/Source Category Description Category
(a) Soil and groundwater remediation operation 9.e.7
(b) Burn out oven 43
(c) Chrome plating 35
(d) Incinerator/ crematory 31
4) Class IV - Complex Notice of Construction Permit
Complex permits generally include those that don't conform to a template
and involve more complex off-site impact evaluation. They include the
following:
Source/Source Category Description
Article IV,
Exhibit R
Category
(a)
Asphalt plant
15
(b)
Composting
21
(c)
Refuse systems
48
(d)
Rendering
49
(e)
Sewerage systems
50
b. For sources / source categories not listed in Section 10.07.A.1.a, above, NOI and
NOC application review will be assigned to Class I, II, II or IV by the Control
Officer on a case-by-case basis.
Article X - Page 5
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Appendix A - Resolution 08-18
c. For sources with one or more emission points under one NOC application, as
allowed in Section 5.02.G, a separate base fee applies to each emissions unit, or
each group of like-kind emissions units, being installed or modified. A group of
emissions units shall be considered as like-kind if the same set of emission
calculations can be used to characterize emissions from each of the emissions
units.
2. Modification / Revision Fee
a. Equipment Modification Fee
Applicants of sources requesting a change in equipment (e.g., replacement or
substantial alteration of emission control technology) pursuant to Section 5.10.C
of this Regulation shall pay a fee pursuant to the fee schedule.
b. Permit Condition Revision Fee
Applicants of sources requesting a change in conditions pursuant to Section
5.10.C of this Regulation shall pay a fee pursuant to the fee schedule.
3. Additional Fees (for each application)
a. SEPA Review Fee
Where review of an Environmental Impact Statement (EIS), Environmental
Checklist, or an Addendum to, or adoption of, an existing environmental
document pursuant to the State Environmental Policy Act (SEPA) Chapter 197-
11 WAC is required, in association with a NOC or a NOI, the applicant shall pay
a SEPA or EIS review fee pursuant to the fee schedule.
b. Toxics Review Fee
For any new source of air pollution which requires review pursuant to Chapter
173-460 WAC, a toxic air pollutant review fee shall be paid. For sources with
one or more emission points under one NOC application, as allowed in Section
5.02.G, a separate toxic air pollutant review fee applies to each emissions unit, or
each group of like-kind emissions units, being installed or modified. A group of
emissions units shall be considered as like-kind if the same set of emission
calculations can be used to characterize emissions from each of the emissions
units. The toxic air pollutant review fee shall be as follows:
1) Small Quantity Emission Rate (SQER)
For a new source using WAC 173-460-080(2)(e), SQER, to demonstrate
that ambient impacts are sufficiently low to protect human health and
safety, as required WAC 173-460-070 & WAC 173-460, the applicant
shall pay a SQER review fee pursuant to the fee schedule.
2) Dispersion Modeling
For a new source using dispersion screening models (e.g., EPA
SCREEN orTSCREEN) under WAC 173-460-080(2)(c) to demonstrate
that ambient impacts are sufficiently low to protect human health and
safety, as required WAC 173-460-070, the applicant shall pay a
dispersion modeling review fee pursuant to the fee schedule.
Article X - Page 6
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Appendix A - Resolution 08-18
3) Advanced Modeling
For a new source using more refined dispersion models (e.g., EPA ISC3)
under WAC 173-460-080(2)(c) to demonstrate that ambient impacts are
sufficiently low to protect human health and safety, as required WAC
173-460-070; or for a new or modified source using a second tier
analysis under WAC 173-460-090 or a risk management decision under
WAC 173-460-100 to demonstrate that ambient impacts are sufficiently
low to protect human health and safety, as required WAC 173-460-070,
the applicant shall pay the advanced modeling review fee in the fee
schedule.
c. New Source Performance Standards (NSPS) Review Fee
Applicants of any new air pollution source subject to WAC 173-400-115 (NSPS)
and 40 CFR Parts 60 shall pay a NSPS review fee according to the fee schedule.
d. National Emission Standard for Hazardous Air Pollutants (NESHAP) Review Fee
Applicants of any new air pollution source subject to WAC 173-400-075
(NESHAP) and 40 CFR Parts 61 and 63 shall pay a NESHAP fee according to
the fee schedule.
e. Best Available Control Technology (BACT) Review Fee
1) Generic BACT
Where no BACT review is required (e.g., the applicant demonstrates
there is an established and/or recognized BACT standard for the source
category type), a BACT review fee is not applicable.
2) Non-Generic BACT Review
A non-generic BACT review is one where a generic BACT standard is
not applicable and a top-down BACT review is not required. Applicants
of any new air pollution source subject to a non-generic BACT review
shall pay a non-generic BACT review fee according to the fee schedule.
3) Top-Down BACT Review (as described in EPA's Draft New Source
Review Workshop Manual from October 1990 and as summarized
below)
A top-down BACT review is one that requires available control
technologies be ranked in descending order of control effectiveness.
The most stringent or "top" control technology is first examined. That
control technology is established as BACT unless the applicant
demonstrates, and the ((Authority)) Agency concurs, that technical
considerations, energy, environmental, or economic impacts justify a
conclusion that the most stringent technology is not achievable in for the
project being proposed. If the most stringent control technology is
eliminated in this fashion, the next most stringent control technology is
considered, and so on. Applicants of any new air pollution source
subject to a top-down BACT review shall pay a top-down BACT review
fee according to the fee schedule.
Article X - Page 7
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Appendix A - Resolution 08-18
B. Payment of Fees
1. At the Time of Application
The base fee shall be paid at the time of application. Review of the application will not
commence until the applicable base fee is received.
2. After Application
a. Payment of Fees for Complete Applications
The Agency will invoice the owner, operator, or applicant for all other applicable
fees without regard to whether the request(s) associated with this section are
approved or denied.
b. Payment of Fees for Incomplete Applications
If an owner, operator, or applicant notifies SRCAA in writing that an incomplete
application will not be completed or cancels the application (i.e., the application is
neither approved or denied), applicable fees for review performed pursuant to
A.2 and A.3 of this section shall be invoiced. If an application remains
incomplete for more than 3 months, the owner, operator, or applicant shall be
invoiced applicable fees for review performed pursuant to A.2 and A.3 of this
section. If review of the application recommences, applicable review fees apply.
C. Incomplete Applications
Applications not accompanied by the base fee will be considered incomplete. In addition, if
information requested by the Agency is not provided, the application will be considered
incomplete and review of the application will be suspended. Review of the application will
commence, or recommence when applicable, when all required fees and information requested
by the Agency is received. An application will be cancelled if it remains incomplete for more than
18 months from initial receipt. For review of the cancelled application to resume, the applicant
must pay all outstanding invoice fees, if applicable, and resubmit the applicable base fee.
D. Compliance Investigation Fee
Where a compliance investigation is conducted pursuant to Section 5.12 of this Regulation, the
compliance investigation fee shall be assessed pursuant to the fee schedule. The fee shall be
assessed for each emissions unit, or group of like-kind emissions units, being installed or
modified. A group of emissions units shall be considered as like-kind if the same set of emission
calculations can be used to characterize emissions from each of the emissions units.
E. Periodic Fee Review
The Board shall periodically review the fee schedule and determine if the total actual fee revenue
collected and projected fee revenue to be collected pursuant to this Section is sufficient to fully
recover program costs. Any proposed fee revisions shall include opportunity for public review
and comment. Accordingly, the Agency shall account for program costs, including employee
costs and overhead. If the Board determines that the total project fee revenue is either
significantly excessive or deficient for this purpose, then the Board shall amend the fee schedule
to more accurately recover program costs. In general, fees will be greater for permits that are
typically more complex or take more time to review and process.
Article X - Page 8
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M Regional.
Clean AirAgoKy
Spokane
3104 E. Au g u st 5 Ave n u e, S p o kan e, WA 99207 +¦ (509) 477 -4.727 + Fax (509) 4.77 -6 323 +¦ www. sp o ka n e de a n ai r. o rg
WHEREAS, pursuant to the provisions of the Washington Clean Air Act, Chapter 70.94 RCW, the Spokane
Regional Clean Air Agency (SRCAA), was created as a municipal corporation of the State of Washington; and
WHEREAS, SRCAA Regulation I contains Article X - Fees and Charges, Section 10.06 Registration and
Operating Permit Fees For Air Contaminant Sources; and
WHEREAS, RCW 70.94.141 authorizes the Board of an activated authority to adopt, amend and repeal its own
rules and regulations; and
WHEREAS, an amendment to SRCAA Regulation I, Article X, Section 10.06 Registration and Operating Permit
Fees For Air Contaminant Sources, C.2 and C.3 is necessary to facilitate the removal of the amount for each Air
Operating Permit Fee from Regulation I; and
WHEREAS, the Operating Permit Fee amounts will be added to the SRCAA Fee Schedule that has been in place
since 2006 and later consolidated with Resolution 11-30; and
WHEREAS, the Board has considered all verbal testimony submitted at the public hearing on October 3rd, 2013,
and written comments submitted and determined that the proposal is reasonable;
NOW THEREFORE, BE IT RESOLVED that the Board of Directors of SRCAA, hereby adopts the amendments
to SRCAA Regulation I, Article X - Fees and Charges, Section 10.06 Registration and Operating Permit Fees For Air
Contaminant Sources, C.2 and C.3 as shown in Attachment A, effective November 12th, 2013.
A RESOLUTION AMENDING REGULATION I,
ARTICLE X - FEES AND CHARGES SECTION 10.06
REGISTRATION AND OPERATING PERMIT FEES
FOR AIR CONTAMINANT SOURCES
)
)
) RESOLUTION 13-19
1
DATED THIS 3rd DAY OF OCTOBER 2013.
SPOKANE REGIONAL CLEAN AIR AGENCY
Commissioner Al French, Chair
Mayor Patrick Rushing, Vice Chair
Tom Brattebo
ATTEST:
Mayor, Tom Towey
William Dame worth, Director
Jeffrey Corkill
-------
Attachment A
AMENDATORY SECTION
REGULATION I, ARTICLE X, SECTION 10.06
SECTION 10.06 REGISTRATION AND OPERATING PERMIT FEES FOR AIR CONTAMINANT SOURCES
A. Each source required by Article IV, Section 4.01 to be registered, each air operating permit source, and each
source required by Article V, Section 5.02 to obtain an approved Notice of Construction and Application for
Approval is subject to an annual fee for each calendar year, or portion of each calendar year, during which it
operates. The owner or operator shall pay the fee, pursuant to the requirements in Section 10.02. Fees received
pursuant to the registration program or the operating permit program shall not exceed the actual costs of program
administration.
B. The annual fee for each source required by Article IV, Section 4.01 to be registered and that is not subject to
Section 10.06.C. of this Regulation shall be determined by adding all of the applicable fees below:
Registration Fee Categories
Fee
Fee Applicability
Facility Fee A
Per the Fee Schedule
Per Source
Emissions Fee B
Per the Fee Schedule
Per Ton
Emission Point Fee c
Per the Fee Schedule
Per Stack/Point
Synthetic Minor Fee D
Per the Fee Schedule
Per Source
((WEDS Fee 6
Per the Fee Schedule
Per Hour))
A Each source is subject to the fee listed in the fee schedule.
B The additional fee applies to each ton (rounded to the nearest one-tenth of a ton) of each criteria
pollutant, volatile organic compound (VOC), and non-VOC toxic air pollutant emitted.
c The additional fee applies to each stack and other emission points, including sources of fugitive
emissions (e.g., fugitive dust emissions from crushing operations; storage piles; mixing and clean-up
associated with surface coating). For gasoline stations, each gasoline tank vent is an emission point.
D The additional fee applies to each Synthetic Minor.
The additional fee applies to each source required by the Agency to submit an annual emissions
inventory for entry into the Washington Emission Data System (WEDS). SRCAA staff time spent
processing and reviewing WEDS will be tracked in 15 minute increments and charged at the hourly
rates provided in the fee schedule.))
2. The Board shall periodically review the fee schedule for registered sources and determine if the total
projected fee revenue to be collected pursuant to this Section is sufficient to fully recover program costs.
Any proposed fee revisions shall include opportunity for public review and comment. Accordingly, the
Agency shall account for program costs, including employee costs and overhead. If the Board determines
that the total projected fee revenue is either significantly excessive or deficient for this purpose, then the
Board may amend the fee schedule to more accurately recover program costs.
C. The annual fee for each air operating permit source shall be determined as follows:
1. The Board shall periodically review the fees for air operating permit sources and determine if the total
projected fee revenue to be collected pursuant to this Section is sufficient to fully recover program costs.
Any proposed fee revisions shall include opportunity for public review and comment. Accordingly, the
Agency shall account for program costs, including employee costs and overhead. If the Board determines
that the total projected fee revenue is either significantly excessive or deficient for this purpose, then the
Board shall amend the fees to more accurately recover program costs.
-------
2. For sources that are subject to the air operating permit (AOP) program during any portion of the calendar
year, the annual fee shall be determined by adding all of the applicable fees described below
a . Annual base fee per the Fee Schedule.
b . Emission fee per the Fee Schedule.
c . SRCAAtime fee, as determined per the Fee Schedule.
<1 AOP Program Cost Correction, as determined per the Fee Schedule.
e. A share of the assessment by Ecology pursuant to RCW 70.94.162(3'). as determined per the Fee
Schedule.
((a, Annual base fee of $3,000;
& Emission fee of $31.11 per ton of actual emissions from the previous calendar year;
g-. SPvCAA time fee, as determined by the following formula:
Tr (Hi+Hg)xRPC
1 ht
Where,
TFI is the SPvCAA time fee for AOP source, I;
HI is the total SPvCAA staff hours spent on AOP source, not including time spent on Notice of
Construction application reviews, I;
HG is the total general hours SPvCAA staff spent on the AOP program divided by the total number
of sources subject to the AOP program during any portion of the calendar year;
PvPC is the remaining SPvCAA AOP program cost, calculated by subtracting the sum of the
Section 10.06.C.2.a and b. fees from the total SPvCAA AOP program costs; and
HT is the total number of hours SPvCAA staff spent on the AOP program, including total time
spent on the AOP sources and general hours spent on the AOP program.
Note: HI, HG, HT, and PvPC are for the most recent SPvCAA fiscal year.
Note: HI, HG, and HT are obtained from SPvCAA time accounting records.
& AOP Program Cost Correction, as determined by the following formula:
PCCI = AOP Program Cumulative Deficit or Surplus x Fl
FT
Where,
PCCI is the AOP Program Cost Correction assessed to each AOP source, I;
AOP Program Cumulative Deficit or Surplus is the cumulative financial deficit or surplus for
SPvCAA's AOP program at the end of the most recent SPvCAA fiscal year;
Fl is the total individual fee assessed pursuant to Section 10.06.C.2.a., b., and c., of this
Pvegulation; and
-------
FT is the sum of all the individual fees assessed pursuant to Sections 10.06.C.2.a., b., and c. of
this Regulation.
A share of the assessment by Ecology pursuant to RCW 70.94.162(3), as determined by the
following formula:
j _ / ' /X^E
Ft
Where,
I is the individual share of the assessment;
Fl is the total individual fee assessed pursuant to Section 10.06.C.2.a., b., and c. of this
Regulation;
AE is the total Ecology assessment pursuant to RCW 70.94.162(3); and
FT is the sum of all the individual fees assessed pursuant to Sections 10.06.C.2.a., b., and c. of
this Regulation.
For affected units under Section 404 (Acid Deposition Standards) of the Federal Clean Air Act (42 USC
7401 et seq):
a-. For time expended in carrying out the fee eligible activities specified in RCW 70.94, an hourly fee
will be assessed pursuant to the fee schedule; and
& A share of the assessment by Ecology pursuant to RCW 70.94.162(3), as determined by the
following formula:
j _ I'] xAe
Ft
Where,
I is the individual share of the assessment;
Fl is the total individual fee assessed pursuant to Section 10.06.C.3.a. of this Regulation;
AE is the total Ecology assessment pursuant to RCW 70.94.162(3); and
FT is the sum of all the individual fees assessed pursuant to Sections 10.06.C.3.a. of this
Regulation.))
3. For affected units under Section 404 (Acid Deposition Standards) of the Federal Clean Air Act (42 USC
7401 et seq), the air operating permit fee shall be determined by adding all of the applicable fees
described below:
a. For time expended in carrying out the fee eligible activities specified in RCW 70.94, an hourly fee
will be assessed pursuant to the fee schedule; and
b. A share of the assessment by Ecology pursuant to RCW 70.94.162(3), as determined per the Fee
Schedule.
((as determined by the following formula:
FtX/Itt-
J-=-
Where,
Ft
-------
I is the individual share of the assessment;
Fl is the total individual fee assessed pursuant to Section 10.06.C.3.a. of this Regulation;
AE is the total Ecology assessment pursuant to RCW 70.94.162(3); and
FT is the sum of all the individual fees assessed pursuant to Sections 10.06.C.3.a. of this
Regulation.))
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Attachment A
AMENDATORY SECTION
REGULATION I, ARTICLE X, SECTION 10.06
SECTION 10.06 REGISTRATION AND OPERATING PERMIT FEES FOR AIR CONTAMINANT
SOURCES
A. Each source required by Article IV, Section 4.01 to be registered, each air operating permit
source, and each source required by Article V, Section 5.02 to obtain an approved Notice of
Construction and Application for Approval is subject to an annual fee for each calendar year, or
portion of each calendar year, during which it operates. The owner or operator shall pay the fee,
pursuant to the requirements in Section 10.02. Fees received pursuant to the registration
program or the operating permit program shall not exceed the actual costs of program
administration.
B. The annual fee for each source required by Article IV, Section 4.01 to be registered and that is
not subject to Section 10.06.C. of this Regulation shall be determined by adding all of the
applicable fees below:
Registration Fee Categories
Fee
Fee Applicability
Facility Fee A
Per the Fee Schedule
Per Source
Emissions Fee B
Per the Fee Schedule
Per Ton
Emission Point Fee c
Per the Fee Schedule
Per Stack/Point
Synthetic Minor Fee D
Per the Fee Schedule
Per Source
((WEDS Fee 6
Per the Fee Schedule
Per Hour))
A Each source is subject to the fee listed in the fee schedule.
B The additional fee applies to each ton (rounded to the nearest one-tenth of a ton) of
each criteria pollutant, volatile organic compound (VOC), and non-VOC toxic air
pollutant emitted.
c The additional fee applies to each stack and other emission points, including
sources of fugitive emissions (e.g., fugitive dust emissions from crushing operations;
storage piles; mixing and clean-up associated with surface coating). For gasoline
stations, each gasoline tank vent is an emission point.
D The additional fee applies to each Synthetic Minor.
«6-The additional fee applies to each source required by the Agency to submit an
annual emissions inventory for entry into the Washington Emission Data System
(WEDS). SRCAA staff time spent processing and reviewing WEDS will be tracked
in 15 minute increments and charged at the hourly rates provided in the fee
schedule.))
2. The Board shall periodically review the fee schedule for registered sources and
determine if the total projected fee revenue to be collected pursuant to this Section is
sufficient to fully recover program costs. Any proposed fee revisions shall include
opportunity for public review and comment. Accordingly, the Agency shall account for
program costs, including employee costs and overhead. If the Board determines that the
Article X - Page 1
-------
total projected fee revenue is either significantly excessive or deficient for this purpose,
then the Board may amend the fee schedule to more accurately recover program costs.
C. The annual fee for each air operating permit source shall be determined as follows:
1. The Board shall periodically review the fees for air operating permit sources and
determine if the total projected fee revenue to be collected pursuant to this Section is
sufficient to fully recover program costs. Any proposed fee revisions shall include
opportunity for public review and comment. Accordingly, the Agency shall account for
program costs, including employee costs and overhead. If the Board determines that the
total projected fee revenue is either significantly excessive or deficient for this purpose,
then the Board shall amend the fees to more accurately recover program costs.
2. For sources that are subject to the air operating permit (AOP) program during any portion
of the calendar year, the annual fee shall be determined by adding all of the applicable
fees described below
a . Annual base fee per the Fee Schedule.
b . Emission fee per the Fee Schedule.
c . SRCAAtime fee, as determined per the Fee Schedule.
<1 AOP Program Cost Correction, as determined per the Fee Schedule.
e. A share of the assessment by Ecology pursuant to RCW 70.94.162(3'). as
determined per the Fee Schedule.
((a, Annual base fee of $3,000;
& Emission fee of $31.11 per ton of actual emissions from the previous calendar
yQ3p
g-. SPvCAA time fee, as determined by the following formula:
Tr (Hi+Hg)xRPC
1 ht
Where,
TFI is the SPvCAA time fee for AOP source, I;
HI is the total SPvCAA staff hours spent on AOP source, not including time spent
on Notice of Construction application reviews, I;
HG is the total general hours SPvCAA staff spent on the AOP program divided by
the total number of sources subject to the AOP program during any portion of the
calendar year;
PvPC is the remaining SPvCAA AOP program cost, calculated by subtracting the
sum of the Section 10.06.C.2.a and b. fees from the total SPvCAA AOP program
costs; and
Article X - Page 2
-------
HT is the total number of hours SRCAA staff spent on the AOP program,
including total time spent on the AOP sources and general hours spent on the
AOP program.
Note: HI, HG, HT, and PvPC are for the most recent SPvCAA fiscal year.
Note: HI, HG, and HT are obtained from SPvCAA time accounting records.
& AOP Program Cost Correction, as determined by the following formula:
PCCI = AOP Program Cumulative Deficit or Surplus x Fl
FT
Where,
PCCI is the AOP Program Cost Correction assessed to each AOP source, I;
AOP Program Cumulative Deficit or Surplus is the cumulative financial deficit or
surplus for SPvCAA's AOP program at the end of the most recent SPvCAA fiscal
yQ3p
Fl is the total individual fee assessed pursuant to Section 10.06.C.2.a., b., and c.,
of this Pvegulation; and
FT is the sum of all the individual fees assessed pursuant to Sections
10.06.C.2.a., b., and c. of this Pvegulation.
A share of the assessment by Ecology pursuant to PvCW 70.94.162(3), as
determined by the following formula:
Ft
Where,
I is the individual share of the assessment;
Fl is the total individual fee assessed pursuant to Section 10.06.C.2.a., b., and c.
of this Pvegulation;
AE is the total Ecology assessment pursuant to PvCW 70.94.162(3); and
FT is the sum of all the individual fees assessed pursuant to Sections
10.06.C.2.a., b., and c. of this Pvegulation.
For affected units under Section 404 (Acid Deposition Standards) of the Federal Clean
Air Act (42 USC 7401 etseq):
a-. For time expended in carrying out the fee eligible activities specified in PvCW
70.94, an hourly fee will be assessed pursuant to the fee schedule; and
& A share of the assessment by Ecology pursuant to PvCW 70.94.162(3), as
determined by the following formula:
Article X - Page 3
-------
j FixAe
Ft
Where,
I is the individual share of the assessment;
Fl is the total individual fee assessed pursuant to Section 10.06.C.3.a. of this
Regulation;
AE is the total Ecology assessment pursuant to RCW 70.94.162(3); and
FT is the sum of all the individual fees assessed pursuant to Sections
10.06.C.3.a. of this Regulation.))
3. For affected units under Section 404 (Acid Deposition Standards) of the Federal Clean
Air Act (42 USC 7401 et seq), the air operating permit fee shall be determined by adding
all of the applicable fees described below:
a. For time expended in carrying out the fee eligible activities specified in RCW
70.94, an hourly fee will be assessed pursuant to the fee schedule; and
b. A share of the assessment by Ecology pursuant to RCW 70.94.162(3), as
determined per the Fee Schedule.
((as determined by the following formula:
Ft
Where,
I is the individual share of the assessment;
Fl is the total individual fee assessed pursuant to Section 10.06.C.3.a. of this
Regulation;
AE is the total Ecology assessment pursuant to RCW 70.94.162(3); and
FT is the sum of all the individual fees assessed pursuant to Sections
10.06.C.3.a. of this Regulation.))
Article X - Page 4
-------
Spokane
31 04 E. Augusta Avenue. Spokane. WA 99207 +¦ (509) £77-4727 +¦ Fax (509) h77-6328 + www.spokanedeanair.org
A RESOLUTION AMENDING THE CONSOLIDATED FEE )
SCHEDULE TO ADD THE AIR OPERATING FEES PURSUANT ) RESOLUTION 13-20
REGULATION I. ARTICLE X. SECTION 10.06 )
WHEREAS, pursuant to the provisions of the Washington Clean Air Act, Chapter 70.94 RCW, the
Spokane Regional Clean Air Agency was created as a municipal corporation of the State of Washington; and
WHEREAS, RCW 70.94.141 authorizes the Board of an activated authority to adopt, amend and repeal
its own rules and regulations - Spokane Regional Clean Air Agency Regulation I is approved and in place; and
WHEREAS, RCW 70.94.152 authorizes Spokane Regional Clean Air Agency to establish and assess fees
and SRCAA has a Consolidated Fee Schedule in place; and
WHEREAS, adding the Air Operating Permit (AOP) Fees to the Consolidated Fee Schedule provides a
single document containing fees; and
WHEREAS, increasing SRCAA Regulation I, Section 10.06.C.2b emission fee from $31.11 to $58 per
ton will give a greater weighting on the emission component in determining a source's annual AOP fee and is the
same as the current emission fee for registered sources; and
WHEREAS, the Board has considered all verbal testimony submitted at the public hearing on October 3,
2013 and written comments submitted, and determined that the proposal is reasonable;
NOW THEREFORE, BE IT RESOLVED the Board of Directors of Spokane Regional Clean Air Agency
amends the Consolidated Fee Schedule adding 10.06C Air Operating Permit Fees as shown in the attachment,
effective November 12, 2013.
DATED THIS 3rd DAY OF OCTOBER 2013. SPOKANE REGIONAL CLEAN AIR AGENCY
Commissioner A1 French, Chair
Mayor Patrick Rushing, Vice Chair
Jeff Corkill
ATTEST:
Tom Brattebo
William Dameworth, Director
Mayor Tom Towey
-------
Attachment to Resolution 13-20
Spokane Regional Clean Air Agency (SRCAA) Fee Schedule
Listed in chronological order by Section number as referenced in SRCAA Regulation I
9.09.C - Asbestos-Containing Waste Material Temporary Storage Permit
Asbestos-Containing Waste Material Temporary Storage Permit application fee: $65
10.06.B - Annual Registration Fees
Registration Fee Categories
Fee Effective Dates
Fee Applicability
7/1/09
1/1/14
1/1/15
1/1/16
Facility Fee
$201
$220
$241
$264
Per Source
Emissions Fee
$58
$69
$76
$83
Per Ton
Emission Point Fee
$63
$69
$76
$83
Per Stack/Point
Synthetic Minor Fee
$1,394
$1,658
$1,815
$1,988
Per Source
10.06.C - Operating Permit Fees
10.06.C.2.a. Annual base fee: $3,000
10.06.C.2.b. Emission fee: $58 per ton of actual emissions from the previous calendar year;
10.06.C.2.C. SRCAA time fee: The time fee is determined by the following formula:
(Hj +Hg)xRPC
TFj =¦
H„
Where,
TFi is the SRCAA time fee for AOP source, I;
Hi is the total SRCAA staff hours spent on AOP source, not including time spent
on Notice of Construction application reviews, I;
Hg is the total general hours SRCAA staff spent on the AOP program divided by
the total number of sources subject to the AOP program during any portion of the
calendar year;
RPC is the remaining SRCAA AOP program cost, calculated by subtracting the
sum of the Section 10.06.C.2.a and b. fees from the total SRCAA AOP program
costs; and
-------
Ht is the total number of hours SRCAA staff spent on the AOP program,
including total time spent on the AOP sources and general hours spent on the
AOP program.
Note: Hi, Hg, Ht, and RPC are for the most recent SRCAA fiscal year.
Note: Hi, Hg, and Ht are obtained from SRCAA time accounting records.
10.06.C.2.d. AOP Program Cost Correction: Cost Correction is determined by the following formula:
PCCi = AOP Program Cumulative Deficit or Surplus x Fi
Ft
Where,
PCCi is the AOP Program Cost Correction assessed to each AOP source, I;
AOP Program Cumulative Deficit or Surplus is the cumulative financial deficit or
surplus for SRCAA's AOP program at the end of the most recent SRCAA fiscal
year;
Fi is the total individual fee assessed pursuant to Section 10.06.C.2.a., b., and c.,
of this Regulation; and
Ft is the sum of all the individual fees assessed pursuant to Sections
10.06.C.2.a., b., and c. of this Regulation.
10.06.C.2.e. Share of the assessment by Ecology pursuant to RCW 70.94.162(3): The share of
Ecology assessment is determined by the following formula:
Ft
Where,
I is the individual share of the assessment;
Fi is the total individual fee assessed pursuant to Section 10.06.C.2.a., b., and c.
of this Regulation;
Ae is the total Ecology assessment pursuant to RCW 70.94.162(3); and
Ft is the sum of all the individual fees assessed pursuant to Sections
10.06.C.2.a., b., and c. of this Regulation.
For time expended in carrying out the fee eligible activities specified in RCW 70.94, an
hourly fee of $67 will be assessed.
Share of the assessment by Ecology pursuant to RCW 70.94.162(3): The share of the
Ecology assessment is determined by the following formula:
10.6.C.3.a
10.6.C.3.b
-------
j _ FIxAE
Ft
Where,
I is the individual share of the assessment;
Fi is the total individual fee assessed pursuant to Section 10.06.C.3.a. of this
Regulation;
Ae is the total Ecology assessment pursuant to RCW 70.94.162(3); and
Ft is the sum of all the individual fees assessed pursuant to Section 10.06.C.3.a.
of the fee schedule.
10.07 - Notice of Construction (NOC) and Notice of Intent (NOI) Fees
A. Base Fee
Class I - Notice of Intent Permit
(Section 5.08.A.2)
Includes
Exhibit R Cateaorv
Fees
Asphalt plant
15
$1,000
Concrete batch plant / ready mix plant
22
$1,000
Rock crusher
36
$1,000
Class II - Simple Notice of Construction Permit
(conforms to template, minimal off-site impact evaluation)
Includes
Exhibit R Cateaorv
Fees
Boiler and other fuel burning equipment
27
$2,290
Coffee Roaster
20
$2,290
Concrete batch plant / ready mix plant (for first time
operation of temporary / portable sources as referenced
in Section 5.08.A.1)
22
$1,250
Concrete batch plant / ready mix plant
22
$2,290
Dry cleaner
23
$2,290
Emergency generator
52
$2,290
Gasoline station
28
$2,290
Lithographic printing / screen printing
9.e.5
$2,290
Material handling / transfer that exhausts >1,000 acfm
24
$2,290
Rock crusher (for first time operation of temporary /
portable sources as referenced in Section 5.08.A.1)
36
$1,250
Rock crusher
36
$2,290
Spray booth / surface coating operation
57
$2,290
Stationary internal combustion engine
53
$2,290
Sterilizer
9.e.8
$2,290
Stump / wood-waste grinder
54
$2,290
Class III - Standard Notice of Construction Permit
-------
(no template, minimal off-site impact evaluation)
Includes
Exhibit R Category
Fees
Soil and groundwater remediation operation
9.e.7
$3,525
Burn-out oven
43
$3,525
Chrome plating
35
$3,525
Incinerator / crematory
31
$3,525
Class IV - Complex Notice of Construction Permit
(no template, more complex off-site impact evaluation)
Includes
Exhibit R Category
Fees
Asphalt plant (for first time operation of temporary /
portable sources as referenced in Section 5.08.A.1)
15
$1,250
Asphalt plant
15
$5,700
Composting
21
$5,700
Refuse systems
48
$5,700
Rendering
49
$5,700
Sewerage systems
50
$5,700
For sources not listed above, the Control Officer will assign a Class at his/her c
iscretion.
B. Modification / Revision Fee
Description
Fees
Eguipment modification1
1/4 regular fee
Permit condition revision
$700
Complex permit condition revision2
$1200
1 The fee shall be one-half the current fees for a Notice of Construction and Application of
Approval or a Notice of Intent to Install and Operate a Temporary Stationary Source for
that type of source, including the base fee and additional fees set
2 Applied when dispersion modeling, impact analysis or emission calculations are required
that are not covered under C. Additional Fees
C. Additional Fees (added to the Base Fee and Modification / Revision Fee, if applicable)
Description
Fees
SEPA review
$500
Toxics review
SQER
$620
Dispersion modeling
$1,250
Advanced modeling
$1,900
NSPS review
40 CFR 60, Subpart 0003
$450
Other4
$600
NESHAP review
40 CFR 63, Subpart M, N & T5
$1,250
Other
$2,525
BACT review Generic
$175
Non-generic
$625
T op-down
$3,200
3 Non-metallic mineral processing (e.g., rock crusher)
4 Other (e.g., boiler, hot mix asphalt plant, volatile organic liquid storage)
5 Dry cleaner, chrome plater, halogenated solvents
-------
D. Compliance Investigation Fee
Description
Fees
Compliance investigation fee
$385
10.08 - Miscellaneous Fees
A. Miscellaneous Fees
Description
Fees
Miscellaneous
Emission reduction credit
$67/hour
Variance request
$67/hour
Alternate opacity
$67/hour
Other
$67/hour
10.09 - Asbestos Fees
Asbestos Project and Demolition Notification Waiting Period and Fee Schedule
Owner-occupied, single-family residence
Waiting Period
Notification Fee
> 0 In ft and/or > 0 sq ft asbestos
performed by residing owner
Notification Not
Required
Not Applicable
< 10 In ft and/or < 48 sq ft asbestos
NOT performed by residing owner
Notification Not
Required
Not Applicable
> 10 In ft and/or > 48 sq ft asbestos
NOT performed by residing owner
Prior Notice
$0
All Demolition
3 Days
$30
Not owner-occupied, single-family residence
Waiting Period
Notification Fee
< 10 In ft and/or < 48 sq ft asbestos
Notification Not
Required
Not Applicable
10-259 In ft and/or 48-159 sq ft asbestos
3 Days
$250A
260-999 In ft and/or 160-4,999 sq ft asbestos
10 Days
$500A
> 1,000 In ft and/or > 5,000 sq ft asbestos
10 Days
$1,250A'B
All Demolition
10 Days
$250
Additional categories
Waiting Period
Notification Fee
Emergency
Prior Notice
Twice the Regular Fee
Amendment
Prior Notice
$0
Annual Notification (< 259 In ft and/or < 159 sq ft)
Prior Notice
$750
Alternate Asbestos Project Work Practices
10 days
Twice the Regular Fee
Demolition with Nonfriable Roofing
10 days
Twice the Regular Fee
Exception for Hazardous Conditions
10 days
Regular Fee
A Includes demolition fee, if applicable, provided the asbestos removal project and demolition project are
submitted to the Agency on one notification.
B When removing > 2,000 In ft and/or > 10,000 sq ft, an additional fee of $250 shall be paid for each increment of
up to 1,000 In ft beginning at 2,000 In ft and/or each increment of up to 10,000 sq ft beginning at 10,000 sq ft.
-------
10.13 - Outdoor Burning Permit Fees
Type of Outdoor Burning
Advance Application Period
Fee
Residential Land Clearing
10 working days
$200
Social Event Fires
3 working days
$50
Storm or Flood Debris
5 working days
$200
Other Outdoor Burning as defined in Chapter 173-425 WAC
10 working days
$55/hr
10.14 - Paving Waiver Fees
Filing Fee... $50
Hourly Fee... $55/hr
-------
Attachment to Resolution 13-20
Spokane Regional Clean Air Agency (SRCAA) Fee Schedule
Listed in chronological order by Section number as referenced in SRCAA Regulation I
9.09.C - Asbestos-Containing Waste Material Temporary Storage Permit
Asbestos-Containing Waste Material Temporary Storage Permit application fee: $65
10.06.B - Annual Registration Fees
Registration Fee Categories
Fee Effective Dates
Fee Applicability
7/1/09
1/1/14
1/1/15
1/1/16
Facility Fee
$201
$220
$241
$264
Per Source
Emissions Fee
$58
$69
$76
$83
Per Ton
Emission Point Fee
$63
$69
$76
$83
Per Stack/Point
Synthetic Minor Fee
$1,394
$1,658
$1,815
$1,988
Per Source
10.06.C - Operating Permit Fees
10.06.C.2.a. Annual base fee: $3,000
10.06.C.2.b. Emission fee: $58 per ton of actual emissions from the previous calendar year;
10.06.C.2.C. SRCAA time fee: The time fee is determined by the following formula:
(Hj +Hg)xRPC
TFj =¦
H,
Where,
TFi is the SRCAA time fee for AOP source, I;
Hi is the total SRCAA staff hours spent on AOP source, not including time spent
on Notice of Construction application reviews, I;
Hg is the total general hours SRCAA staff spent on the AOP program divided by
the total number of sources subject to the AOP program during any portion of the
calendar year;
RPC is the remaining SRCAA AOP program cost, calculated by subtracting the
sum of the Section 10.06.C.2.a and b. fees from the total SRCAA AOP program
costs; and
-------
Ht is the total number of hours SRCAA staff spent on the AOP program,
including total time spent on the AOP sources and general hours spent on the
AOP program.
Note: Hi, Hg, Ht, and RPC are for the most recent SRCAA fiscal year.
Note: Hi, Hg, and Ht are obtained from SRCAA time accounting records.
10.06.C.2.d. AOP Program Cost Correction: Cost Correction is determined by the following formula:
PCCi = AOP Program Cumulative Deficit or Surplus x Fi
Ft
Where,
PCCi is the AOP Program Cost Correction assessed to each AOP source, I;
AOP Program Cumulative Deficit or Surplus is the cumulative financial deficit or
surplus for SRCAA's AOP program at the end of the most recent SRCAA fiscal
year;
Fi is the total individual fee assessed pursuant to Section 10.06.C.2.a., b., and c.,
of this Regulation; and
Ft is the sum of all the individual fees assessed pursuant to Sections
10.06.C.2.a., b., and c. of this Regulation.
10.06.C.2.e. Share of the assessment by Ecology pursuant to RCW 70.94.162(3): The share of
Ecology assessment is determined by the following formula:
Ft
Where,
I is the individual share of the assessment;
Fi is the total individual fee assessed pursuant to Section 10.06.C.2.a., b., and c.
of this Regulation;
Ae is the total Ecology assessment pursuant to RCW 70.94.162(3); and
Ft is the sum of all the individual fees assessed pursuant to Sections
10.06.C.2.a., b., and c. of this Regulation.
For time expended in carrying out the fee eligible activities specified in RCW 70.94, an
hourly fee of $67 will be assessed.
Share of the assessment by Ecology pursuant to RCW 70.94.162(3): The share of the
Ecology assessment is determined by the following formula:
10.6.C.3.a
10.6.C.3.b
-------
j _ FIxAE
Ft
Where,
I is the individual share of the assessment;
Fi is the total individual fee assessed pursuant to Section 10.06.C.3.a. of this
Regulation;
Ae is the total Ecology assessment pursuant to RCW 70.94.162(3); and
Ft is the sum of all the individual fees assessed pursuant to Section 10.06.C.3.a.
of the fee schedule.
10.07 - Notice of Construction (NOC) and Notice of Intent (NOI) Fees
A. Base Fee
Class I - Notice of Intent Permit
(Section 5.08.A.2)
Includes
Exhibit R Cateaorv
Fees
Asphalt plant
15
$1,000
Concrete batch plant / ready mix plant
22
$1,000
Rock crusher
36
$1,000
Class II - Simple Notice of Construction Permit
(conforms to template, minimal off-site impact evaluation)
Includes
Exhibit R Cateaorv
Fees
Boiler and other fuel burning equipment
27
$2,290
Coffee Roaster
20
$2,290
Concrete batch plant / ready mix plant (for first time
operation of temporary / portable sources as referenced
in Section 5.08.A.1)
22
$1,250
Concrete batch plant / ready mix plant
22
$2,290
Dry cleaner
23
$2,290
Emergency generator
52
$2,290
Gasoline station
28
$2,290
Lithographic printing / screen printing
9.e.5
$2,290
Material handling / transfer that exhausts >1,000 acfm
24
$2,290
Rock crusher (for first time operation of temporary /
portable sources as referenced in Section 5.08.A.1)
36
$1,250
Rock crusher
36
$2,290
Spray booth / surface coating operation
57
$2,290
Stationary internal combustion engine
53
$2,290
Sterilizer
9.e.8
$2,290
Stump / wood-waste grinder
54
$2,290
Class III - Standard Notice of Construction Permit
-------
(no template, minimal off-site impact evaluation)
Includes
Exhibit R Category
Fees
Soil and groundwater remediation operation
9.e.7
$3,525
Burn-out oven
43
$3,525
Chrome plating
35
$3,525
Incinerator / crematory
31
$3,525
Class IV - Complex Notice of Construction Permit
(no template, more complex off-site impact evaluation)
Includes
Exhibit R Category
Fees
Asphalt plant (for first time operation of temporary /
portable sources as referenced in Section 5.08.A.1)
15
$1,250
Asphalt plant
15
$5,700
Composting
21
$5,700
Refuse systems
48
$5,700
Rendering
49
$5,700
Sewerage systems
50
$5,700
For sources not listed above, the Control Officer will assign a Class at his/her c
iscretion.
B. Modification / Revision Fee
Description
Fees
Eguipment modification1
1/4 regular fee
Permit condition revision
$700
Complex permit condition revision2
$1200
1 The fee shall be one-half the current fees for a Notice of Construction and Application of
Approval or a Notice of Intent to Install and Operate a Temporary Stationary Source for
that type of source, including the base fee and additional fees set
2 Applied when dispersion modeling, impact analysis or emission calculations are required
that are not covered under C. Additional Fees
C. Additional Fees (added to the Base Fee and Modification / Revision Fee, if applicable)
Description
Fees
SEPA review
$500
Toxics review
SQER
$620
Dispersion modeling
$1,250
Advanced modeling
$1,900
NSPS review
40 CFR 60, Subpart 0003
$450
Other4
$600
NESHAP review
40 CFR 63, Subpart M, N & T5
$1,250
Other
$2,525
BACT review Generic
$175
Non-generic
$625
T op-down
$3,200
3 Non-metallic mineral processing (e.g., rock crusher)
4 Other (e.g., boiler, hot mix asphalt plant, volatile organic liquid storage)
5 Dry cleaner, chrome plater, halogenated solvents
-------
D. Compliance Investigation Fee
Description
Fees
Compliance investigation fee
$385
10.08 - Miscellaneous Fees
A. Miscellaneous Fees
Description
Fees
Miscellaneous
Emission reduction credit
$67/hour
Variance request
$67/hour
Alternate opacity
$67/hour
Other
$67/hour
10.09 - Asbestos Fees
Asbestos Project and Demolition Notification Waiting Period and Fee Schedule
Owner-occupied, single-family residence
Waiting Period
Notification Fee
> 0 In ft and/or > 0 sq ft asbestos
performed by residing owner
Notification Not
Required
Not Applicable
< 10 In ft and/or < 48 sq ft asbestos
NOT performed by residing owner
Notification Not
Required
Not Applicable
> 10 In ft and/or > 48 sq ft asbestos
NOT performed by residing owner
Prior Notice
$0
All Demolition
3 Days
$30
Not owner-occupied, single-family residence
Waiting Period
Notification Fee
< 10 In ft and/or < 48 sq ft asbestos
Notification Not
Required
Not Applicable
10-259 In ft and/or 48-159 sq ft asbestos
3 Days
$250A
260-999 In ft and/or 160-4,999 sq ft asbestos
10 Days
$500A
> 1,000 In ft and/or > 5,000 sq ft asbestos
10 Days
$1,250A'B
All Demolition
10 Days
$250
Additional categories
Waiting Period
Notification Fee
Emergency
Prior Notice
Twice the Regular Fee
Amendment
Prior Notice
$0
Annual Notification (< 259 In ft and/or < 159 sq ft)
Prior Notice
$750
Alternate Asbestos Project Work Practices
10 days
Twice the Regular Fee
Demolition with Nonfriable Roofing
10 days
Twice the Regular Fee
Exception for Hazardous Conditions
10 days
Regular Fee
A Includes demolition fee, if applicable, provided the asbestos removal project and demolition project are
submitted to the Agency on one notification.
B When removing > 2,000 In ft and/or > 10,000 sq ft, an additional fee of $250 shall be paid for each increment of
up to 1,000 In ft beginning at 2,000 In ft and/or each increment of up to 10,000 sq ft beginning at 10,000 sq ft.
-------
10.13 - Outdoor Burning Permit Fees
Type of Outdoor Burning
Advance Application Period
Fee
Residential Land Clearing
10 working days
$200
Social Event Fires
3 working days
$50
Storm or Flood Debris
5 working days
$200
Other Outdoor Burning as defined in Chapter 173-425 WAC
10 working days
$55/hr
10.14 - Paving Waiver Fees
Filing Fee... $50
Hourly Fee... $55/hr
-------
August 16, 2006
Semiannual Title V Permit Data Report
This information request is authorized pursuant to the Information Collection Request for Part 70 Operating
Permit Regulations, EPA Number 1587.06, OMB Number 2060-0243; April 2004.
Permitting Authority:
Spokane Regional Clean Air Agency
Report Date:
7/10/18
Reporting Period:
^January 01 - June 30, 2018
*Report due July 31*
~July 01 - December 31, 2017
*Report due January 31*
Data Element
Reported Value
Information
1. Outstanding
Permit
Issuance
a) Number of final actions:
n/a
• Total final actions on Permitting Authority-specific
permit issuance commitments (i.e., agreements by
the Permitting Authority to complete action on initial
permits within a specified time-frame, such as
agreements related to the 2001 citizen comments).
• If the Permitting Authority does not have a
commitment, enter "not applicable" in 1(a) and 1(b).
b) Total commitment
universe:
n/a
c) Date commitment
completed (if applicable):
2. Total Current
Part 70
Source
Universe and
Permit
Universe
a) Number of active part 70
sources that have
obtained part 70 permits,
plus the number of
active part 70 sources
that have not yet
obtained part 70 permits:
8
• The total current Dart 70 source universe includes all
sources subject to the Permitting Authority's part 70
program applicability requirements (i.e., provisions
comparable to §70.3).
• In 2.a), count all active sources that either have
obtained or will obtain a part 70 permit. EPA expects
that this data will be primarily based on the Permitting
Authority's application and permit tracking information.
If, however, the Permitting Authority is aware of part 70
sources that are not yet captured by application or
permit information, count those sources as well.
• Do not count sources that are no longer subject to part
70, such as sources that have shut down, or become
natural minors or synthetic minors, and do not have an
active part 70 permit.
• Do not double count sources included in 2.b).
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August 16, 2006
Total Current
Part 70
Source
Universe and
Permit
Universe
(Continued)
b) Number of part 70
sources that have
applied to obtain a
synthetic minor
restriction in lieu of a
part 70 permit, and the
part 70 program's permit
application due dates for
those sources have
passed:
0
• Element 2.b) is intended to capture the universe of
part 70 sources that are seeking synthetic minor
restrictions in lieu of part 70 permits, but haven't
received those restrictions before becoming subject
to the part 70 program's permit application
requirements. If the part 70 applications don't readily
identify sources seeking such restrictions, the
Permitting Authority may include those sources in
2.a), and need not break them out here. However,
EPA expects Permitting Authorities to consider
pending synthetic minor requests not addressed in
part 70 applications to calculate this portion of the
part 70 source universe.
• Count sources that currently meet the part 70
program's applicability requirements, their part 70
application due dates have passed, and they have
requested but not yet received synthetic minor
restrictions in lieu of a part 70 permit (or permit
renewal).
• Also count active sources whose synthetic minor
restrictions have expired (i.e., no synthetic minor
restrictions are currently in place, even though they
may be eligible for such restrictions) and are past
their part 70 program's application due date.
• Do not count sources that have active synthetic minor
restrictions and are no longer subject to part 70.
• Do not double count sources included in 2(a).
c) Total number of current
part 70 sources (a+b):
8
d) For permitting
authorities that issue
multiple part 70 permits
to a single source: total
number of active part 70
Dermits issued. dIus Dart
70 oermits aoolied for:
n/a
• For Permitting Authorities that issue multiple part 70
permits to a single source, and these permits are
issued and tracked separately, report the total permit
universe, including # of active part 70 permits issued
(element 3 below), plus permits applied for (based on
pending applications). This information is for
correlating data when the Permitting Authority's part
70 Dermit universe mav be areaterthan the Dart 70
source universe.
• For Permitting Authorities that do not issue multiple
permits to a single source, or for those that issue and
track multiple permits issued to a source on a
source-wide basis, enter "not applicable" in 2.d).
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August 16, 2006
3. Total Active
Part 70
Permits
Total number of active part
70 permits:
8
• This element includes all active initial and renewal part
70 permits issued by the permitting authority. Do not
count inactive permits, i.e., permits that are no longer
in effect due to source shutdown, synthetic minor
restrictions, etc. Note: the procedures for rendering
part 70 permits no longer effective may vary,
depending on the part 70 program.
• Do not count both initial and renewal permits (or prior
renewal and current renewal permits) issued to the
same source; i.e., do not double count.
• Count permits that have been extended (see 6.b.
below), but do not count permits that have expired, or
have been voided, revoked, etc.
• Count each source covered by a general permit
separately for this data element. If a single source has
several general permits and/or source specific permits,
refer to the information for permitting authorities that
issue multiple part 70 permits to a single source.
• For permitting authorities that issue multiple part 70
permits to a single source and included information in
element 2(d), count each permitted portion of the
source separately for this element. This distinction is
for correlating this data element with the permit
universe information in element #2(d).
4. Timeliness of
Initial Permits
(PART
element)
a) Total number of initial
part 70 permits issued
during 6 month reporting
period:
0
• This data element tracks the initial part 70 permits
issued as final (e.g., not draft or proposed) during the 6
month reporting period covered by this report, and
whether they were issued within 18 months of receipt
of an administratively complete application.
• For TOPS purposes, initial permits are permits that are
issued to any source that has become subject to part
70 for the first time, or any source that comes back into
the part 70 program after a period of not being subject.
• If no initial permits were issued during the 6 month
reporting period, report "zero" in 4(b), and "not
applicable" in 4(a).
• Start the 18-month clock on the submittal date of an
administratively complete application. For purposes
of this data element, do not stop or restart the 18
month clock for additional information submitted after
the application is deemed administratively complete.
• For permitting authorities that issue multiple part 70
permits to a single source and included information in
2(d), count each permitted portion of the source
separately for this element. This distinction is for
determining individual permit timeliness.
b) Number of initial part 70
permits finalized during 6
month reporting period
that were issued within
18 months:
n/a
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August 16, 2006
5. Total
Outstanding
Initial Part 70
Applications
The number of active initial
part 70 applications
older than 18 months:
0
• This element tracks all active, administratively
complete initial part 70 permit applications that the
permitting authority has not taken final action on within
18 months of receipt of the administratively complete
application. Do not stop or restart the 18 month clock
for additional information submitted after the
application is deemed administratively complete.
• For TOPS purposes, initial part 70 applications are
applications for sources that are subject to title V for
the first time, or for any source that comes back into
the title V program after a period of not being subject.
Do not include renewal applications.
• Include all current outstanding initial applications,
including those that may also be tracked in data
element#!
• Do not count initial applications the Permitting
Authority has taken final action on.
6. Outstanding
Renewal
Permit
Actions
a) Total number of expired
permits for active part 70
sources:
0
• This data element tracks the total number of expired
permits for active part 70 sources. Part 70 permits
expire after 5 years if the sources do not submit timely
and complete renewal applications, or if they have lost
their application shield by not timely responding to
additional requests for information.
• Include expired permits that have been addressed
through consent orders or other enforcement
mechanisms. Expired permits can be further
addressed in the "Additional Information" element.
• Do not include permits that have expired because the
source is no longer subject to Title V; i.e., they have
shutdown or have received synthetic minor restrictions.
For permitting authorities that issue multiple part 70
permits to a single source and included information in
2(d), count each expired permit separately.
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August 16, 2006
Outstanding
Renewal
Permit
Actions
(Continued)
b) Total number of active
permits with terms
extended past 5 years:
1
City of Spokane Waste-to-
Energy facility permit
expired on 5/27/18
• This data element tracks the total number of active
permits that have been extended past the original 5
year permit term. Part 70 permits or permit conditions
are extended beyond the original 5 year term when
sources submit a timely and complete renewal
application (and any timely and complete additional
information requested by the permitting authority), but
the permitting authority has not yet issued a renewal
permit.
• Count all extended permits, including extended permits
for sources that submitted timely and complete
renewal applications within the last 18 months.
Pending applications that are less than 18 months old
can be further addressed in the "Additional Information'
element.
• Do not include inactive extended permits, i.e., when a
subsequent permit renewal has been issued or a
source is no longer subject to part 70.
• Do not include "expired part 70 permits" that have
been addressed through consent orders or other
enforcement mechanisms. Count expired permits in
6(a).
• For permitting authorities that issue multiple part 70
permits to a single source and included information in
2(d), count each extended permit separately.
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August 16, 2006
7. Timeliness of
Significant
Modifications
(PART
element - a
and b only)
a) Total number of
significant modifications
issued during 6 month
reporting period:
0
• This data element tracks the number of significant
modifications issued as final (e.g., not draft or
proposed) during the 6 month reporting period. It also
tracks the number of those modifications that were
issued within 18 months of receipt of an
administratively complete significant modification
application, and also the number that were issued
within 9 months. Note that 7(c) is a subset of 7(b).
• If no significant modifications were issued during the 6
month reporting period, report "zero" in 7(a) and "not
applicable" in 7(b) and 7(c).
• Start the application clock on the submittal date of an
administratively complete significant modification
application. Do not restart the clock for additional
information submissions.
b) Number of significant
modifications finalized
during 6 month reporting
period that were issued
within 18 months:
n/a
c) Number of significant
modifications finalized
during 6 month reporting
period that were issued
within 9 months:
n/a
8. Outstanding
Significant
Permit
Modifications
Total number of active
significant modification
applications older than 18
months:
1
City of Spokane Waste-to-
Energy facility -
modifications will be rolled
into next renewal permit
• This element tracks all active, administratively
complete significant permit modification applications
that the permitting authority has not taken final action
on within 18 months of receipt of the administratively
complete application.
• Do not stop or restart the 18 month clock for
additional information submitted after the application
is deemed administratively complete.
• Do not count significant modification applications the
Permitting Authority has taken final action on.
9. Comments
and
Additional
Information
Permitting authorities may provide any additional
information in this section. For example, a permitting
authority may address data changes, data management
issues, general permits, multiple permits issued to single
stationary sources, synthetic minor information, additional
relevant data, etc.
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